Miscellaneous Rules Applicable to Certain Offshore Activities. 1. The provisions of this Article shall apply notwithstanding any other provision of this Convention where activities (in this Article called "relevant activities") are carried on offshore in connection with the exploration or exploitation of the sea bed and subsoil and their natural resources situated in a Contracting State.
2. An enterprise of a Contracting State which carries on relevant activities in the other Contracting State shall, subject to paragraph 3 of this Article, be deemed to be carrying on business in that other State through a permanent establishment situated therein.
3. Relevant activities which are carried on by an enterprise of a Contracting State in the other Contracting State for a period or periods not exceeding in the aggregate 30 days within any period of twelve months shall not constitute the carrying on of business through a permanent establishment situated therein. For the purposes of this paragraph:
(a) where an enterprise of a Contracting State carrying on relevant activities in the other Contracting State is associated with another enterprise carrying on substantially similar relevant activities there, the former enterprise shall be deemed to be carrying on all such activities of the latter enterprise, except to the extent that those activities are carried on at the same time as its own activities;
(b) an enterprise shall be regarded as associated with another enterprise if one participates directly or indirectly in the management, control or capital of the other or if the same persons participate directly or indirectly in the management, control or capital of both enterprises.
4. Salaries, wages and similar remuneration derived by a resident of a Contracting State in respect of an employment connected with relevant activities in the other Contracting State may, to the extent that the duties are performed offshore in that other State, be taxed in that other State.
5. Gains derived by a resident of a Contracting State from the alienation of:
(a) exploration or exploitation rights; or
(b) shares (or comparable instruments) deriving their value or the greater part of their value directly or indirectly from such rights, may be taxed in that other State. In this paragraph "exploration or exploitation rights" mean rights to assets to be produced by the exploration or exploitation of the seabed or subsoil or their natural resources in the other Contracting State, including rights to interests in or to the benefit of such assets.
Miscellaneous Rules Applicable to Certain Offshore Activities. 1. The provisions of this Article shall apply notwithstanding any other provision of this Agreement.
2. In this Article the term “offshore activities” means activities which are carried on offshore in a Territory in connection with the exploration or exploitation of the seabed and subsoil and their natural resources situated in that Territory.
Miscellaneous Rules Applicable to Certain Offshore Activities. 1. The provisions of this Article shall apply notwithstanding any other provision of this Agreement where activities (in this Article called “relevant activities”) are carried on offshore in connection with the exploration or exploitation of the sea bed and subsoil and their natural resources situated in a Contracting State.
2. An enterprise of a Contracting State which carries on relevant activities in the other Contracting State shall, subject to paragraph 3 of this Article, be deemed to be carrying on business in that other State through a permanent establishment situated therein.
3. The provisions of paragraph 2 shall not apply where the activities referred to in paragraph 1 are carried on in the areas specified in that paragraph for a period not exceeding a total of:
a) in the case of activities in connection with exploration, 90 days in any period of twelve months commencing or ending in the fiscal year concerned; and
b) in the case of activities in connection with exploitation, 30 days in any period of twelve months commencing or ending in the fiscal year concerned.
4. Salaries, wages and similar remuneration derived by a resident of a Contracting State in respect of an employment connected with relevant activities in the other Contracting State may, to the extent that the duties are performed offshore in that other State, be taxed in that other State.
5. Gains derived by a resident of a Contracting State from the alienation of:
a) exploration or exploitation rights; or
b) shares ( or comparable instruments) deriving their value or the greater part of their value directly or indirectly from such rights, may be taxed in that other State. In this paragraph “exploration or exploitation rights” mean rights to assets to be produced by the exploration or exploitation of the seabed or subsoil or their natural resources in the other Contracting State, including rights to interests in or to the benefit of such assets.
Miscellaneous Rules Applicable to Certain Offshore Activities. 1. The provisions of this Article shall apply notwithstanding any other provision of this Agreement where activities (in this Article called “relevant activities”) are carried on offshore in connection with the exploration or exploitation of the seabed and subsoil and their natural resources situated in a Contracting State.
2. An enterprise of a Contracting State which carries on relevant activities in the other Contracting State shall, subject to paragraph 3 of this Article, be deemed to be carrying on business in that other State through a permanent establishment situated therein.
3. Relevant activities which are carried on by an enterprise of a Contracting State in the other Contracting State for a period or periods not exceeding in the aggregate 30 days within any period of twelve months shall not constitute the carrying on of business through a permanent establishment situated therein. For the purposes of this paragraph:
(a) where an enterprise of a Contracting State carrying on relevant activities in the other Contracting State is associated with another enterprise carrying on substantially sim ilar relevant activities there, the form er enterprise shall be deemed to be carrying on all such activities of the latter enterprise, except to the extent that those activities are carried on at the same xxx e as its own activities;
(b) an enterprise shall be regarded as associated with another enterprise if one participates directly or indirectly in the management, control or capital of the other or if the same persons participate directly or indirectiy in the management, control or capital of both enterprises.
Miscellaneous Rules Applicable to Certain Offshore Activities. 1. The provisions of this Article shall apply notwithstanding any other provision of this Convention.
2. In this Article the term "offshore activities" means activities which are carried on offshore in connection with the exploration or exploitation of the seabed and subsoil and their natural resources situated in a Contracting State.
Miscellaneous Rules Applicable to Certain Offshore Activities. 1. The provisions of this Article shall apply, notwithstanding any other provision of this Convention, where activities (in this Article called "relevant activities") are carried on offshore in connection with the exploration or exploitation of the sea bed and subsoil and their natural resources situated in a Contracting State.
Miscellaneous Rules Applicable to Certain Offshore Activities. The provisions of this Article shall apply notwithstanding any other provision of this Convention where activities are carried on offshore (in this Article called "offshore activities") in connection with the exploration or exploitation or the sea bed and sub-soil and their natural resources situated in a Contracting State.
Miscellaneous Rules Applicable to Certain Offshore Activities. The provisions of this Article shall apply notwithstanding any other provision of this Convention.
