1.  Profits from the operation of ships or aircraft in international traffic shall be taxable only in the State in which the place of management and control of the enterprise is situated.

2.  If the place of management and control of a shipping enterprise is aboard a ship, then it shall be deemed to be situated in the State in which the home harbour of the ship is situated, or, if there is no such home harbour, in the State of which the operator of the ship is a resident.

3.  The provisions of paragraph 1 shall also apply to profits from the participation in a pool, a joint business or an international operating agency.

3.  Furthermore the Netherlands shall allow a deduction from Netherlands tax computed in accordance with the preceding paragraphs of this Article with respect to the items of income which according to Articles 11 (paragraph 2) and 14 (paragraph 6) of this Convention may be taxed in Singapore and are included in the basis mentioned in paragraph 1 of this Article. The amount of this deduction shall be equal to the tax paid in Singapore on these items of income, but shall not exceed the amount of the Netherlands tax which bears the same relation to the amount of tax computed in conformity with paragraph 1 of this Article, as the amount of the items of income mentioned in this paragraph bears to the amount of income which forms the basis mentioned in paragraph 1.

1.  This Protocol shall enter into force on the thirtieth day after the latter of the dates on which the respective Governments have notified each other in writing that the formalities constitutionally required in their respective States have been complied with, and its provisions shall have effect

2.  Notwithstanding the provisions of paragraph 1 of this Article and of Article II of this Protocol, where interest or royalties arising in Singapore are paid to a resident of the Netherlands, the provisions of paragraphs 3, 4 and 5 of Article 24 of the Convention shall continue to apply to such interest or royalties until the first day of January of the year 2000. However, in no case shall this paragraph apply to interest or royalties paid after December 31, 1999, or to interest or royalties which relate to periods after that date irrespective of when they are paid. The provisions of the first sentence of this paragraph shall not apply if the debt-claim in respect of which the interest is paid or the right or property giving rise to the royalties was agreed upon or assigned mainly for the purpose of taking advantage of the provisions of paragraphs 4 and 5 of Article 24 of the Convention. Further, the provisions of the first sentence of this paragraph shall only apply to interest paid in respect of loans, or royalties paid in respect of contracts, for the purpose of and directly connected with projects for the economic development of Singapore.

3.  This Protocol shall remain in effect as long as the Convention remains in force.