OFFSHORE ACTIVITIES. 1. The provisions of this Article shall apply notwithstanding any other provision of this Convention.
2. A person who is a resident of a Contracting State and carries on activities off- shore in the other Contracting State in connection with the exploration or exploitation of the seabed and subsoil and their natural resources situated in that other State shall, sub- ject to paragraphs 3 and 4 of this Article, be deemed in relation to those activities to be carrying on business in that other State through a permanent establishment or fixed base situated therein.
3. The provisions of paragraph 2 and sub-paragraph b) of paragraph 6 shall not apply where the activities are carried on for a period not exceeding 30 days in the aggregate in any twelve months period commencing or ending in the fiscal year concerned. However, for the purposes of this paragraph:
a) Where an enterprise of a Contracting State carrying on offshore activities in the other Contracting State is associated with another enterprise carrying on substantially similar offshore activities there, the former enterprise shall be deemed to be carrying on all such activities of the latter enterprise, with the exception of activities which 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 person or persons participate directly or indirectly in the management, control or capital of both enterprises.
4. Profits derived by a resident of a Contracting State from the transportation of supplies or personnel to a location, or between locations, where activities in connection with the exploration or exploitation of the seabed and subsoil and their natural resources are being carried on in a Contracting State, or from the operation of tugboats and other vessels auxiliary to such activities, shall be taxable only in the Contracting State of which the enterprise is a resident.
5. a) Subject to sub-paragraph b) of this paragraph, salaries, wages and similar remuneration derived by a resident of a Contracting State in respect of an employment connected with the exploration or exploitation of the seabed and subsoil and their natural resources situated 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. However, such remuneration shall be taxable...
OFFSHORE ACTIVITIES. (1) The provisions of this Article shall apply notwithstanding the provisions of Articles 4 to 20 of this Convention.
(2) For the purposes of this Article, the term "offshore activities" means activities carried on offshore in a Contracting State in connection with the exploration or exploitation of the sea bed and sub-soil and their natural resources situated in that State.
OFFSHORE ACTIVITIES. 1. The provisions of this Article shall apply notwithstanding any other provisions of this Convention. However, this Article shall not apply where offshore activities of a person constitute for that person a permanent establishment under the provisions of Article 5 or a fixed base under the provisions of Article 14.
2. In this Article the term “offshore activities” means activities which are carried on offshore in connection with the exploration or exploitation of the sea bed and its sub-soil and their natural resources, situated in a Contracting State.
OFFSHORE ACTIVITIES. Contractor shall not access or transmit nor permit any agent or subcontractor to access, transmit, move, ship, mail or in any way convey or communicate any protected information to a location outside of the United States of America without the advance written consent of County.
OFFSHORE ACTIVITIES. 1. The provisions of this Article shall apply notwithstanding any other provision of this Convention.
2. A person who is a resident of a Contracting State and carries on activities offshore in the other Contracting State in connection with the exploration or exploitation of the seabed and subsoil and their natural resources situated in that other State shall, subject to paragraph 3 of this Article, be deemed in relation to those activities to be carrying on business in that other State through a permanent establishment or fixed base situated therein.
3. The provisions of paragraph 2 shall not apply where the activities are carried on for a period or periods not exceeding 30 days in the aggregate in any twelve month period. However, for the purposes of this paragraph:
(a) activities carried on by an enterprise associated with another enterprise shall be regarded as carried on by the enterprise with which it is associated if the activities in question are substantially the same as those carried on by the last-mentioned enterprise;
(b) two enterprises shall be deemed to be associated if one is controlled directly or indirectly by the other, or both are controlled directly or indirectly by a third person or persons.
4. Salaries, wages and similar remuneration derived by a resident of a Contracting State in respect of an employment connected with the exploration or exploitation of the seabed and subsoil and their natural resources situated 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 provided that the employment offshore is carried on for a period or periods exceeding 30 days in the aggregate in any twelve month period.
5. Gains derived by a resident of a Contracting State from the alienation of:
(a) exploration or exploitation rights; or
(b) property situated in the other Contracting State and used in connection with the exploration or exploitation of the seabed and subsoil and their natural resources situated in that other State; or
(c) shares deriving their value or the greater part of their value directly or indirectly from such rights or such property or from such rights and such property taken together, may be taxed in that other State. In this paragraph "exploration or exploitation rights" means rights to assets to be produced by the exploration or exploitation of the seabed and subsoil and their natural resources in the other Contracting State, including rights...
OFFSHORE ACTIVITIES. 1. The provisions of this Article shall apply notwithstanding the provisions of Articles 4 to 20 of this Convention.
2. A person who is a resident of a Contracting State and carries on activities offshore in the other Contracting State in connection with the exploration or exploitation of the sea bed and sub-soil and their natural resources situated in that other State shall, subject to paragraphs 3 and 4, be deemed in relation to those activities to be carrying on business in that other State through a permanent establishment or fixed base situated therein.
3. The provisions of paragraph 2 shall not apply, where the activities are carried on for a period or periods not exceeding in the aggregate 30 days in any twelve-month period. However, for the purposes of this paragraph:
(a) activities carried on by a person who is associated with another person shall be regarded as carried on by the other person if the activities in question are substantially the same as those carried on by the first-mentioned person, except to the extent that those activities are carried on at the same time as its own activities;
(b) a person shall be deemed to be associated with another person if one is controlled directly or indirectly by the other, or both are controlled directly or indirectly by a third person or third persons.
4. Profits derived by a resident of a Contracting State from the transportation of supplies or personnel to a location, or between locations, where activities in connection with the exploration or exploitation of the sea bed and sub-soil and their natural resources are being carried on in a Contracting State, or from the operation of tugboats and other vessels auxiliary to such activities, shall be taxable only in the first-mentioned State.
(a) Subject to sub-paragraph (b) of this paragraph, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment connected with the exploration or exploitation of the sea bed and sub-soil and their natural resources situated 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. However, such remuneration shall be taxable only in the first-mentioned State if the employment is carried on offshore for an employer who is not a resident of the other State and for a period or periods not exceeding in the aggregate 30 days in any twelve-month period.
(b) Salaries, wages and other sim...
OFFSHORE ACTIVITIES. 1. The provisions of this Article shall apply notwithstanding any other provision of this Agreement.
2. A person who is a resident of Singapore and carries on activities offshore in Norway in connection with the exploration or exploitation of the seabed and subsoil and their natural resources situated in Norway shall, subject to paragraphs 3 and 4 of this Article, be deemed in relation to those activities to be carrying on business in Norway through a permanent establishment or fixed base situated therein.
3. The provisions of paragraph 2 shall not apply where the activities are carried on for a period not exceeding 30 days in the aggregate in any twelve month period. However, for the purposes of this paragraph:
(a) activities carried on by an enterprise associated with another enterprise shall be regarded as carried on by the enterprise with which it is associated if the activities in question are substantially the same as those carried on by the last-mentioned enterprise;
(b) two enterprises shall be deemed to be associated if one is controlled directly or indirectly by the other, or both are controlled directly or indirectly by a third person or persons.
4. Profits derived by a resident of Singapore from the transportation of supplies or personnel to a location, or between locations, where activities in connection with the exploration or exploitation of the seabed and subsoil and their natural resources are being carried on in Norway, or from the operation of tugboats and other vessels auxiliary to such activities, shall be taxable only in Singapore.
(a) Subject to sub-paragraph (b) of this paragraph, salaries, wages and similar remuneration derived by a resident of Singapore in respect of an employment connected with the exploration or exploitation of the seabed and subsoil and their natural resources situated in Norway may, to the extent that the duties are performed offshore in Norway, be taxed in Norway. However, such remuneration shall be taxable only in Singapore if the employment is carried on offshore for an employer who is not a resident of Norway and for a period or periods not exceeding in the aggregate 30 days in any twelve-month period.
(b) Salaries, wages and similar remuneration derived by a resident of Singapore in respect of an employment exercised aboard a ship or aircraft engaged in the transportation of supplies or personnel to a location, or between locations, where activities connected with the exploration or exploitation of the se...
OFFSHORE ACTIVITIES. The insurance by this insured section is extended to cover liability to an employee for bodily injury caused by visits, work or activities undertaken offshore except that the insurer shall not be liable to pay any amount in excess of a sub-limit of indemnity stated in the schedule in respect of:
a) any one claim against the insured or series of claims against the insured; and
b) any claim or series of claims made by the insured under this insured section; arising out of one occurrence.
OFFSHORE ACTIVITIES. 1. Notwithstanding the provisions of Article 5 and Article 14, a person who is a resident of a Contracting State and carries on activities offshore in the other Contracting State in connection with the exploration or exploitation of the seabed and subsoil and their natural resources situated in that other State shall be deemed in relation to those activities to be carrying on business in that other State through a permanent establishment or fixed base situated therein.
2. Paragraph 1 of this Article shall not apply where a resident of a Contracting State carries on transportation of supplies or personnel to a location, or between locations, where activities in connection with the exploration or exploitation of the seabed and subsoil and their natural resources are being carried on in the other Contracting State, or operated tugboats and other vessels auxiliary to such activities.
3. Notwithstanding the provisions of Article 13, gains derived by a resident of a Contracting State from the alienation of:
a. exploration or exploitation rights; or
b. property situated in the other Contracting State and used in connection with exploration or exploitation of the seabed and subsoil and their natural resources situated in that other State; or
c. shares deriving their value or the greater part of their value directly or indirectly from such rights or such property or from such rights and such property taken together, may be taxed in that other State. In this paragraph "exploration or exploitation rights" means rights to assets to be produced by the exploration or exploitation of the seabed and subsoil and their natural resources in the other Contracting State, including rights to interests in or to the benefit of such assets.
OFFSHORE ACTIVITIES. 1 The provisions of this Article shall apply notwithstanding any other provision of this Convention.
2 A person who is a resident of a Contracting State and carries on activities offshore in the other Contracting State in connection with the exploration or exploitation of the seabed or subsoil or their natural resources situated in that other State shall, subject to paragraph 3 of this Article, be deemed in relation to those activities to be carrying on business in that other State through a permanent establishment situated therein.
