The Double Taxation Relief (Taxes on Income) (India) Order 1993

Article 9 Shipping

(1) Income of an enterprise of a Contracting State from the operation of ships in international traffic shall be taxable only in that State.

(2) The provisions of paragraph (1) of this Article shall not apply to income from journeys between places which are situated in a Contracting State.

(3) For the purposes of this Article, income from the operation of ships includes income derived from the rental on a bareboat basis of ships if such rental income is incidental to the income described in paragraph (1) of this Article.

(4) Notwithstanding the provisions of Article 7 (Business profits) of this Convention, the provisions of paragraphs (1) and (2) of this Article shall likewise apply to income of an enterprise of a Contracting State from the use, maintenance or rental of containers (including trailers and related equipment for the transport of containers) used for the transport of goods or merchandise.

(5) The provisions of this Article shall apply also to income derived from participation in a pool, a joint business or an international operating agency.

(6) Gains derived by an enterprise of a Contracting State from the alienation of ships or containers owned and operated by the enterprise shall be taxed only in that State if either the income from the operation of the alienated ships or containers was taxed only in that State, or the ships or containers are situated outside the other Contracting State at the time of the alienation.