Common use of OFFSHORE ACTIVITIES Clause in Contracts

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 on- ly 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 peri- ods not exceeding in the aggregate 30 days in any twelve-month period.

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 offshore in the other Contracting State in connection with the exploration or exploitation of the seabed sea bed and subsoil sub-soil and their natural resources situated in that other State shall, sub- ject subject to paragraphs 3 and 4 of this Article4, 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 apply, where the activities are carried on for a period or periods not exceeding in the aggregate 30 days in the aggregate in any twelve months period commencing or ending in the fiscal year concernedtwelve-month period. However, for the purposes of this paragraph: a) Where an enterprise of activities carried on by a Contracting State carrying on offshore activities in the other Contracting State person who is associated with another enterprise carrying person shall be regarded as carried on by the other person if the activities in question are substantially similar offshore activities there, the former enterprise same as those carried on by the first-mentioned person; b) a person 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 person if one participates is controlled directly or indirectly in by the managementother, control or capital of the other or if the same person or persons participate both are controlled directly or indirectly in the management, control by a third person or capital of both enterprisesthird 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 seabed sea bed and subsoil 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 Contracting State of which the enterprise is a residentfirst-mentioned State. 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 sea bed and subsoil 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 on- ly 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 peri- ods periods not exceeding in the aggregate 30 days in any twelve-month period.

OFFSHORE ACTIVITIES. 1. The provisions of this Article shall apply notwithstanding any other provision 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 off- shore offshore in the other Contracting State in connection with the exploration or exploitation of the seabed sea bed and subsoil sub-soil and their natural resources situated in that other State shall, sub- ject subject to paragraphs 3 and 4 of this Article4, 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 apply, where the activities are carried on for a period or periods not exceeding in the aggregate 30 days in the aggregate in any twelve months period commencing or ending in the fiscal year concernedmonth period. However, for the purposes of this paragraph: a) Where an enterprise of activities carried on by a Contracting State carrying on offshore activities in the other Contracting State person who is associated with another enterprise carrying on substantially similar offshore activities there, the former enterprise person shall be deemed 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 be carrying on all such the extent that those 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 a person shall be regarded as deemed to be associated with another enterprise person if one participates is controlled directly or indirectly in by the managementother, control or capital of the other or if the same person or persons participate both are controlled directly or indirectly in the management, control by a third person or capital of both enterprisesthird 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 seabed sea bed and subsoil 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 Contracting State of which the enterprise is a residentfirst- mentioned State. 5. 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 seabed sea bed and subsoil 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 on- ly 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 peri- ods periods not exceeding in the aggregate 30 days in any twelve-twelve month period.

OFFSHORE ACTIVITIES. 1. The provisions of this Article shall apply notwithstanding any other provision of this ConventionAgreement. 2. A person who is a resident of a Contracting State and carries on activities off- shore offshore in the other Contracting State in connection with the exploration or exploitation of the seabed and or subsoil and or their natural resources situated in that other State shall, sub- ject subject 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 concernedperiod. However, for the purposes of this paragraph: a) Where activities carried on by an enterprise of a Contracting State carrying on offshore activities in the other Contracting State is associated with another enterprise carrying shall be regarded as carried on by the enterprise with which it is associated if the activities in question are substantially similar offshore activities there, the former enterprise same as those carried on by the last-mentioned enterprise; b) two enterprises 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 is controlled directly or indirectly in by the managementother, control or capital of the other or if the same person or persons participate both are controlled directly or indirectly in the management, control by a third person or capital of both enterprisespersons. 4. Profits derived by a resident an enterprise 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 or subsoil and or 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 or subsoil and or 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 on- ly 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 provided that the employment is carried on for a period or peri- ods periods not exceeding in the aggregate 30 days in any twelve-month period.

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 offshore in the other Contracting State in connection with the exploration or exploitation of the seabed and or subsoil and or their natural resources situated in that other State shall, sub- ject subject 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 period of twelve months period commencing or ending in the fiscal year concerned. However, for the purposes of this paragraph: a) Where activities carried on by an enterprise of a Contracting State carrying on offshore activities in the other Contracting State is associated with another enterprise carrying shall be regarded as carried on by the enterprise with which it is associated if the activities in question are substantially similar offshore activities there, the former enterprise same as those carried on by the last-mentioned enterprise; b) two enterprises 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 is controlled directly or indirectly in by the managementother, control or capital of the other or if the same person or persons participate both are controlled directly or indirectly in the management, control by a third person or capital of both enterprisespersons. 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 or subsoil and or 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. This provision shall not apply if the vessel or aircraft is operated by a permanent establishment in the sense of Article 5, or the activities are continued for more than six months in any twelve month period. 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 or subsoil and or 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 on- ly 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 provided the employment is carried on for a period or peri- ods periods not exceeding in the aggregate 30 days in any twelve-month periodperiod of twelve months commencing or ending in the fiscal year concerned.

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 offshore in the other Contracting State in connection with the exploration or exploitation of the seabed sea bed and subsoil sub- soil and their natural resources situated in that other State shall, sub- ject subject to paragraphs 3 and 4 of this Article4, 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 apply, where the activities are carried on for a period or periods not exceeding in the aggregate 30 days in the aggregate in any twelve months period commencing or ending in the fiscal year concernedtwelve-month period. However, for the purposes of this paragraph: a) Where an enterprise of activities carried on by a Contracting State carrying on offshore activities in the other Contracting State person who is associated with another enterprise carrying person shall be regarded as carried on by the other person if the activities in question are substantially similar offshore activities there, the former enterprise same as those carried on by the first-mentioned person; b) a person 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 person if one participates is controlled directly or indirectly in by the managementother, control or capital of the other or if the same person or persons participate both are controlled directly or indirectly in the management, control by a third person or capital of both enterprisesthird 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 seabed sea bed and subsoil 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 Contracting State of which the enterprise is a residentfirst-mentioned State. 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 sea bed and subsoil 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 on- ly 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 peri- ods periods not exceeding in the aggregate 30 days in any twelve-month period. b) Salaries, wages and similar remuneration derived by a resident of a Contracting State 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 sea bed and sub-soil and their natural resources are being carried on in a Contracting State, or in respect of an employment exercised aboard tugboats or other vessels operated auxiliary to such activities, may be taxed in the Contracting State of which the employer is a resident. 6. 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 sea bed and sub-soil 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 the term "exploration or exploitation rights" means rights to assets to be produced by the exploration or exploitation of the sea bed and sub-soil 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 off- shore offshore in the other Contracting State in connection with the exploration or exploitation of the seabed sea bed and subsoil sub- soil and their natural resources situated in that other State shall, sub- ject subject to paragraphs 3 and 4 of this Article4, 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 apply, where the activities are carried on for a period or periods not exceeding in the aggregate 30 days in the aggregate in any twelve months period commencing or ending in the fiscal year concernedtwelve-month period. However, for the purposes of this paragraph: a) Where an enterprise of activities carried on by a Contracting State carrying on offshore activities in the other Contracting State person who is associated with another enterprise carrying person shall be regarded as carried on by the other person if the activities in question are substantially similar offshore activities there, the former enterprise same as those carried on by the first-mentioned person; b) a person 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 person if one participates is controlled directly or indirectly in by the managementother, control or capital of the other or if the same person or persons participate both are controlled directly or indirectly in the management, control by a third person or capital of both enterprisesthird 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 seabed sea bed and subsoil 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 Contracting State of which the enterprise is a residentfirst-mentioned State. 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 sea bed and subsoil 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 on- ly only in the first-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 peri- ods periods not exceeding in the aggregate 30 days in any twelve-month period.

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 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, sub- ject subject 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 or periods 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: aa. 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: (i) 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 an enterprise of the other Contracting State, or if  (ii) 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) 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 on- ly 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 peri- ods periods not exceeding in the aggregate 30 days in any twelve-month periodmonths period commencing or ending in the fiscal year concerned. b. Salaries, wages and similar remuneration derived by a resident of a Contracting State 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 seabed and subsoil and their natural resources are being carried on in the other Contracting State, or in respect of an employment exercised aboard tugboats or other vessels operated auxiliary to such activities, may be taxed in the Contracting State of which the enterprise carrying on such activities is a resident. 6. 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 or subsoil or 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 paragraph shall apply notwithstanding any other provision the preceding provisions of this ConventionArrangement. 2. A person who is a resident of a Contracting State and carries In this paragraph, `relevant activities` means activities which are carried on activities off- shore in the other Contracting State offshore in connection with the exploration or exploitation of the seabed sea- bed and subsoil sub-soil and their natural resources situated in that one of the territories. 3. An enterprise of one of the territories which carries on relevant activities in the other State shallterritory shall in respect of those activities, subject to sub- ject paragraphs (4) to paragraphs 3 and 4 (7) of this Articleparagraph, be deemed in relation to those activities to be carrying on business in that other State territory through a permanent establishment or fixed base situated therein. 34. The provisions Relevant activities which are carried on by an enterprise of paragraph 2 and one of the territories in the other territory for a period or periods not exceeding in the aggregate 30 days in any period of 12 months shall not constitute the carrying on of business through a permanent establishment situated therein. 5. For the purposes of sub-paragraph b(4) 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 , where an enterprise of a Contracting State one of the territories carrying on offshore relevant activities in the other Contracting State territory is associated with another enterprise carrying on substantially similar offshore relevant activities there, the former enterprise shall be deemed to be carrying on all such activities of the latter enterprise, with except to the exception of extent that those activities which are carried on at the same time as its own activities;. b6. For the purposes of sub-paragraph (5) An of this paragraph, an enterprise shall be regarded as associated with another enterprise if - a. one participates directly or indirectly in the management, control or capital of the other or if other; or b. the same person or persons participate directly or indirectly in the management, control or capital of both enterprises. 47. Profits derived by a resident an enterprise of a Contracting State one of the territories from - a. the transportation of supplies from a port in that territory by a ship or personnel aircraft to a location, location or between locations, locations in the other territory where relevant activities are being carried on; or b. the operation of tug boats registered in and normally operating from a port in that territory 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 residentthat territory. 58. a) A resident of one of the territories who carries on relevant activities in the other territory, which consist of professional services or other activities of an independent character, shall be deemed to be performing those activities from a fixed base in that other territory, but income derived by a resident of one of the territories in respect of such activities performed in the other territory shall not be taxable in that other territory if the activities are performed in the other territory for a period or periods not exceeding in the aggregated 30 days in any period of 12 months. 9. Subject to sub-paragraph b(10) of this paragraph, salaries, wages and similar remuneration derived by a resident of a Contracting State one of the territories in respect of an employment connected with the exploration or exploitation of the seabed and subsoil and their natural resources situated relevant activities in the other Contracting State territory may, to the extent that the duties are performed offshore in that other Stateterritory, be taxed in that other State. However, such remuneration shall be taxable on- ly 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 peri- ods not exceeding in the aggregate 30 days in any twelve-month periodterritory.

OFFSHORE ACTIVITIES. 1. The provisions of this Article shall apply have effect notwithstanding any other provision of this Convention. 2. A person who is a resident of a Contracting State and carries on activities off- shore offshore in the other Contracting State in connection with the exploration or exploitation of the seabed sea-bed and subsoil sub-soil and their natural resources situated in that other State shall, sub- ject subject 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 concernedmonths' period. However, for the purposes of this paragraph: (a) Where activities carried on by an enterprise of a Contracting State carrying on offshore activities in the other Contracting State is associated with another enterprise carrying shall be regarded as carried on by the enterprise with which it is associated if the activities in question are substantially similar offshore activities there, the former enterprise same as those carried on by the last-mentioned enterprise; (b) two enterprises 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 is controlled directly or indirectly in by the managementother, control or capital of the other or if the same person or persons participate both are controlled directly or indirectly in the management, control by a third person or capital of both enterprisespersons. 4. Profits derived by Paragraph 2 of this Article shall not apply where a resident of a Contracting State from the 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 sea-bed and subsoil sub-soil and their natural resources are being carried on in a the other Contracting State, or from the operation of operate 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 sea-bed and subsoil 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 on- ly in the first-mentioned State if provided that the employment offshore is carried on offshore for an employer who is a period exceeding 30 days in the aggregate in any twelve months' period. (b) Sub-paragraph (a) of this paragraph shall not apply to salaries, wages and similar remuneration derived by a resident of a Contracting State 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 sea-bed and sub-soil and their natural resources are being carried on in the other Contracting State, or in respect of an employment exercised aboard tugboats or other vessels operated auxiliary to such activities. 6. 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 for a period used in connection with the exploration or peri- ods not exceeding exploitation of the sea-bed and sub-soil 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 and exploitation rights" means rights to assets to be produced by the exploration or exploitation of the sea-bed and sub-soil and their natural resources in the aggregate 30 days other Contracting State, including rights to interests in any twelve-month periodor to the benefit of such assets.

OFFSHORE ACTIVITIES. 1. The provisions of this Article shall apply have effect notwithstanding any other provision provisions of this Convention. 2. A person who is a resident of residenot f a Contracting State and carries on activities off- shore 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, sub- ject subject to paragraphs 3 and 4 n3d a4 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 areiecdarorn for a period not exceeding 30 days in the aggregate in any twelve months period commencing or ending in the fiscal year concernedtw-meloventh period. However, for the purposes of this paragraph: a) Where activities carried on by an enterprise of a Contracting State carrying on offshore activities in the other Contracting State is associated with another enterprise carrying shall be regarded as carried on by the entreisrpe with which it is associated if the activities in question are substantially similar offshore activities there, the former enterprise same as those carried on by the last-mentioned enterprise; b) two enterprises 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 is controlled directly or indirectly in by the managementother, control or capital of the other or if the same person or persons participate both are controlled directly or indirectly in by a third person or persons, or if one is engaged by the management, control or capital of both enterprisesother enterprise to perform a particular service. 4. Profits derived by a resident of a Contracting State from the transportation of supplies or personnel personenl 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 velsssaeuxiliary to such activities, shall may be taxable only taxed in the Contracting State in which the place of which effective management of the enterprise is situated. However, such profits arising in the Philippines may also be taxed in the Philippines but the tax so chargehdasll not exceed the lesser of: (i) 8 per cent of the gross amount received, or (ii) the lowest rate of Philippine tax imposed on such profits derived by an enterprise of a residentthird State under similar circumstances. 5. a) Subject to subsu-paragraph bparagraph (b) of this tihs 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 Caocntitnrg State mayshall, to the extent that the duties are performed offshore in that other State, be taxed taxable only in that other State. However, such remuneration shall be taxable on- ly in the first-mentioned State if provided that the employment offshore is carried on offshore for an employer who is not a resident of the other State and for a period or peri- ods not exceeding 30 days in the aggregate 30 days in any twelve-tw- elve month period.

OFFSHORE ACTIVITIES. 1. The provisions of this Article shall apply notwithstanding any other provision of this Convention. 2. A person persan who is a resident of a Contracting State and carries on activities off- shore offshore in the other Contracting State in connection with the exploration or exploitation of the seabed and or subsoil and or their natural resources situated in that other State shall, sub- ject subject 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 5 shall not net apply where the activities are carried on for a period not net 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 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: (i) 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 contrai or capital of an enterprise of the other Contracting State, or (ii) The same persan or if the same person or persons persans participate directly or indirectly in the management, control contrai or at least 30% of the capital of both enterprises. 4. Profits derived by a resident an enterprise 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 or subsoil and or their natural resources are being carried on in a Contracting State, or from the operation of tugboats and other vessels vessais 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 or subsoil and or 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 on- ly only in the first-mentioned State if the employment empioyment is carried on offshore for an employer who is not a resident of the other State and provided that the employment is carried on for a period or peri- ods periods not exceeding in the aggregate 30 days in any twelve-month periodperiod commencing or ending in the fiscal year concerned.

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 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, sub- ject subject 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 or periods not exceeding 30 days in the aggregate in any twelve months period commencing or ending in the fiscal year concernedperiod. However, for the purposes of this paragraph: a) Where activities carried on by an enterprise of a Contracting State carrying on offshore activities in the other Contracting State is associated with another enterprise carrying shall be regarded as carried on by the enterprise with which it is associated if the activities in question are substantially similar offshore activities there, the former enterprise same as those carried on by the last- mentioned enterprise; b) two enterprises 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 is controlled directly or indirectly in by the managementother, control or capital of the other or if the same person or persons participate both are controlled directly or indirectly in the management, control by a third person or capital of both enterprisespersons. 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. This provision shall not apply if the vessel or aircraft is operated by a permanent establishment in the sense of Article 5 of this Convention. 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 extend that the duties are performed offshore in that other State, be taxed in that other State. However, such remuneration shall be taxable on- ly only in the first-mentioned State if the employment is carried on offshore for an employer who is not a resident of the other Contracting State and for a period or peri- ods periods not exceeding in the aggregate 30 days in any twelve-month months period. b) Salaries, wages and similar remuneration derived by a resident of a Contracting State 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 seabed and subsoil and their natural resources are being carried on in the other Contracting State, or in respect of an employment exercised aboard tugboats or other vessels operated auxiliary to such activities, may be taxed in the Contracting State of which the enterprise carrying on such activities is a resident. This provision shall not apply if the vessel or aircraft is operated by a permanent establishment in the sense of Article 5 of this Convention. 6. 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 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 ) An enterprise of a Contracting State and which carries on activities off- shore offshore in the other Contracting State in connection with the exploration or exploitation of the seabed sea-bed and subsoil and their natural resources situated in that areas which are, in accordance with international law, under the jurisdiction of the other Contracting State shall, sub- ject subject to paragraphs 3 and 4 of this Article5, be deemed in relation to those activities deemed, except as regards paragraph 2 of Article 14, to be carrying on in respect of those activities a business in that other Contracting 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 referred to therein are carried on in the areas specified in that paragraph for a period not exceeding 30 a total of: a) in the case of activities in connection with exploration, 90 days in the aggregate in any period of twelve months period 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) However, for the purposes of this paragraph: a) Where paragraph 3, where an enterprise of a Contracting State carrying on offshore activities referred to in the other Contracting State paragraph 2 in those specified areas 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 enterprise except to the exception of extent that those 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 is controlled directly or indirectly in by the managementother, control or capital of the other or if the same person or persons participate both are controlled directly or indirectly in the management, control by a third person or capital of both enterprisespersons. 4. 5) Profits derived by a resident of a Contracting State from the transportation of supplies or personnel to a location, or between locations, location where activities in connection with the exploration or exploitation of the seabed sea-bed and subsoil and their natural resources are being carried on in areas which are under the jurisdiction of a Contracting State, State or from the operation of tugboats and other similar vessels auxiliary to in connection with such activities, shall be taxable only in the Contracting State of which the enterprise he 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 on- ly 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 peri- ods not exceeding in the aggregate 30 days in any twelve-month period.

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 offshore in the other Contracting State in connection with the exploration or exploitation of the seabed sea bed and subsoil sub-soil and their natural resources situated in that other State shall, sub- ject subject to paragraphs 3 and 4 of this Article4, 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 apply, where the activities are carried on for a period or periods not exceeding in the aggregate 30 days in the aggregate in any twelve months period commencing or ending in the fiscal year concernedmonth period. However, for the purposes of this paragraph: (a) Where an enterprise of activities carried on by a Contracting State carrying on offshore activities in the other Contracting State person who is associated with another enterprise carrying person shall be regarded as carried on by the other person if the activities in question are substantially similar offshore activities there, the former enterprise same as those carried on by the first- mentioned person; (b) a person 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 person if one participates is controlled directly or indirectly in by the managementother, control or capital of the other or if the same person or persons participate both are controlled directly or indirectly in the management, control by a third person or capital of both enterprisesthird 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 seabed sea bed and subsoil 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 Contracting State of which the enterprise is a residentfirst- mentioned State. 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 sea bed and subsoil 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 on- ly 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 peri- ods periods not exceeding in the aggregate 30 days in any twelve-twelve month period. (b) Salaries, wages and similar remuneration derived by a resident of a Contracting State 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 sea bed and sub-soil and their natural resources are being carried on in a Contracting State, or in respect of an employment exercised aboard tugboats or other vessels operated auxiliary to such activities, may be taxed in the Contracting State of which the employer is a resident. 6. Gains derived by a resident of a Contracting State from the alienation of: (a)exploration or exploitation rights; or

OFFSHORE ACTIVITIES. 1. The provisions of this Article shall apply notwithstanding any other provision of this ConventionAgreement. 2. A person who is a resident of a Contracting State and carries on activities off- shore offshore in the other Contracting State in connection with the exploration or exploitation of the seabed and or subsoil and or their natural resources situated in that other State shall, sub- ject subject 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 concernedperiod. However, for the purposes of this paragraph: a) Where a. activities carried on by an enterprise of a Contracting State carrying on offshore activities in the other Contracting State is associated with another enterprise carrying shall be regarded as carried on by the enterprise with which it is associated if the activities in question are substantially similar offshore activities there, the former enterprise same as those carried on by the last-mentioned enterprise; b. two enterprises 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 is controlled directly or indirectly in by the managementother, control or capital of the other or if the same person or persons participate both are controlled directly or indirectly in the management, control by a third person or capital of both enterprisespersons. 4. Profits derived by a resident an enterprise 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 or subsoil and or 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) 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 or subsoil and or 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 on- ly 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 provided that the employment is carried on for a period or peri- ods periods not exceeding in the aggregate 30 days in any twelve-month period. b. Salaries, wages and similar remuneration derived by a resident of a Contracting State 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 seabed or subsoil or their natural resources are being carried on in the other Contracting State, or in respect of an employment exercised aboard tugboats or other vessels operated auxiliary to such activities, may be taxed in the Contracting State of which the enterprise carrying on such activities is a resident. 6. 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 or subsoil or 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 or subsoil or 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 provisions of this Convention. 2. A person who is a resident of a Contracting State and carries on activities off- shore offshore in the other Contracting State in connection with the exploration or exploitation of the seabed sea bed and subsoil sub-soil and their natural resources situated in that other State shall, sub- ject subject to paragraphs 3 and 4 of this Article4, 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 apply, where the activities are carried on for a period or periods not exceeding in the aggregate 30 days in the aggregate in any twelve months period commencing or ending in the fiscal year concernedtwelve-month period. However, for the purposes of this paragraph: a) Where an enterprise of activities carried on by a Contracting State carrying on offshore activities in the other Contracting State person who is associated with another enterprise carrying person shall be regarded as carried on by the other person if the activities in question are substantially similar offshore activities there, the former enterprise same as those carried on by the firstmentioned person; b) a person 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 person if one participates is controlled directly or indirectly in by the managementother, control or capital of the other or if the same person or persons participate both are controlled directly or indirectly in the management, control by a third person or capital of both enterprisesthird 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 seabed sea bed and subsoil 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 Contracting State of which the enterprise is a residentfirst-mentioned State. 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 sea bed and subsoil 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 on- ly 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 peri- ods periods not exceeding in the aggregate 30 days in any twelve-month period.

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 subject to paragraphs 3 and 4 of this Article, be deemed in relation to those activities to be carrying on a business in that other State through a permanent establishment or fixed base situated therein. 3. The provisions of paragraph 2 and sub-paragraph subparagraph b) of paragraph 6 shall not apply where the activities referred to therein are carried on for a period or periods not exceeding in the aggregate 30 days in the aggregate in any twelve months period commencing or ending in the fiscal year concerned12- month period. However, for the purposes of this paragraph: a) Where 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;; and b) An enterprise two enterprises shall be regarded as deemed to be associated with another enterprise if one participates directly or indirectly in the management, management or control or capital of the other other, or if the same person or persons participate directly or indirectly in the management, management or control or capital of both enterprises. 4. Profits derived by a resident an enterprise of a Contracting State from the transportation of supplies or personnel by ship or aircraft 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 first-mentioned State. The provisions of which the enterprise is a residentthis paragraph shall apply only when such ships, vessels or aircraft are operated in international traffic. 5. a) Subject to sub-paragraph subparagraph 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 on- ly 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 peri- ods periods not exceeding in the aggregate 30 days in any twelve12-month period.; and

OFFSHORE ACTIVITIES. 1. The provisions of this Article shall apply notwithstanding any other provision of this ConventionAgreement. 2. A person who is a resident of a Contracting State and carries on activities off- shore offshore in the other Contracting State in connection with the exploration or exploitation of the seabed and or subsoil and or their natural resources situated in that other State shall, sub- ject subject 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 paragraphparagraph : (a) Where 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;; and (b) An enterprise two enterprises shall be regarded as deemed to be associated with another enterprise if one participates is controlled directly or indirectly in by the managementother, control or capital of the other or if the same person or persons participate both are controlled directly or indirectly in the management, control by a third person or capital of both enterprises.persons; 4. Profits derived by a resident an enterprise of a Contracting State from the transportation of supplies or personnel to or from a location, or between locations, where activities in connection with the exploration or exploitation of the seabed and or subsoil and or their natural resources are being carried on in a the other 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. Notwithstanding the provisions of this paragraph, profits derived from such operation may also be taxed in the Contracting State in which the operation is carried on; but the tax so charged shall not exceed 50 per cent of the tax otherwise imposed by the domestic law of that State. For the purposes of this paragraph, the amount of such profits subject to tax in India shall not exceed 7.5 per cent of the sums receivable. 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 or subsoil" or their natural resources situated in the other Contracting State mayState, to the extent that the duties are performed offshore in that other State, may be taxed in that other State. However, such remuneration shall be taxable on- ly 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 provided that the employment is carried on for a period or peri- ods periods not exceeding in the aggregate 30 days in any twelve-month periodperiod commencing or ending in the fiscal year concerned. (b) Salaries, wages and similar remuneration derived by a resident of a Contracting State in respect of an employment exercised aboard a ship or aircraft engaged in the transportation of supplies or personnel to or from a location, or between locations, where activities connected with the exploration or exploitation of the seabed or subsoil or their natural resources are being carried on in the other Contracting State, or in respect of an employment exercised aboard tugboats or other vessels operated auxiliary to such activities, may be taxed, in the Contracting State of which the enterprise carrying on such activities is a resident.

OFFSHORE ACTIVITIES. 1. The provisions of this Article shall apply notwithstanding any other provision provisions of this ConventionAgreement. 2. A person who is a resident of a Contracting State and carries on offshore activities off- shore in the other Contracting State in connection with the exploration or exploitation of the seabed sea-bed and subsoil sub- soil and their natural resources situated in that other State shall, sub- ject subject to paragraphs 3 and 4 of this Article4, 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 or periods not exceeding in the aggregate 30 days in the aggregate in any twelve months period commencing or ending in the fiscal year concernedtwelve-month period. However, for the purposes of this paragraph: a) Where an enterprise of activities carried on by a Contracting State carrying on offshore activities in the other Contracting State person who is associated with another enterprise carrying person shall be regarded as carried on by the other person if the activities in question are substantially similar offshore activities there, the former enterprise same as those carried on by the first-mentioned person; b) a person 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 person if one participates is controlled directly or indirectly in by the managementother, control or capital of the other or if the same person or persons participate both are controlled directly or indirectly in the management, control by a third person or capital of both enterprisesthirds 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 seabed sea-bed and subsoil 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 Contracting State of which the enterprise is a residentfirst-mentioned State. 5. a) Subject to sub-paragraph subparagraph 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 sea-bed and subsoil sub-soil and their natural resources situated in the other Contracting State may, to the extent extend that the duties are performed offshore in that other State, be taxed in that other State. However, such remuneration shall be taxable on- ly 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 peri- ods periods not exceeding in the aggregate 30 days in any twelve-month period.

OFFSHORE ACTIVITIES. 1. The provisions of this Article shall apply notwithstanding any other provision the provisions of Articles 4 to 20 of this Convention. 2. A person who is In this Article the term offshore activities means activities which are carried on offshore in 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 its subsoil and their natural resources situated in that Contracting State. 3. An enterprise of a Contracting State which carries on offshore activities in the other Contracting State shall, sub- ject subject to paragraphs 3 and 4 of this Articleparagraph 4, be deemed in relation to those activities to be carrying on business in that other Contracting State through a permanent establishment or fixed base situated therein. 34. The provisions of paragraph 2 and sub-paragraph b) of paragraph 6 3 shall not apply where the offshore activities are carried on in the other Contracting State for a period or periods not exceeding 30 days in the aggregate thirty days in any twelve months period commencing or ending in the fiscal year concernedmonth period. However, for For the purposes of this paragraph: a) Where 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 first-mentioned enterprise shall be deemed to be carrying on all such activities of the latter other enterprise, with except to the exception of extent that those activities which are carried on at the same time as its own activities; b) An b. an enterprise shall be regarded as considered to be associated with another enterprise if one either participates directly or indirectly in the management, control or capital of the other enterprise or if the same person or group of persons participate participates directly or indirectly in the management, control or capital of both enterprises. 45. Profits derived by a A resident of a Contracting State from the transportation of supplies or personnel to a location, or between locations, where who carries on offshore activities in connection with the exploration or exploitation of the seabed and subsoil and their natural resources are being carried on in a other Contracting State, consisting of rendering professional services or from the operation other services of tugboats and other vessels auxiliary to such activities, an independent character shall be taxable only considered to be performing his activities from a fixed base, in the Contracting State of which the enterprise is a residentthat other State. 56. a) Subject to sub-paragraph b) of this paragraph7, 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 offshore 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. 7. HoweverSalaries, such wages and similar remuneration shall be taxable on- ly in the first-mentioned State if the employment is carried on offshore for an employer who is not derived by a resident of a Contracting State in respect of an employment exercised on board a ship or aircraft engaged in the transportation of supplies or personnel to a location where activities connected with the exploration or exploitation of the seabed and its subsoil and their natural resources are being carried on in a Contracting State, or in respect of any employment exercised on board a tugboat or other vessels auxiliary to such activities, may be taxed in the Contracting State of which the enterprise is a resident. 8. 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 for a period used in connection with the exploration or peri- ods not exceeding exploitation of the seabed and its 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 the term “exploration or exploitation rights” means rights to assets to be produced by the exploration or exploitation of the seabed and its subsoil and their natural resources in the aggregate 30 days other Contracting State, including rights to interests in any twelve-month periodor to the benefit of such assets.

OFFSHORE ACTIVITIES. 1. The provisions of this Article shall apply notwithstanding any other provision 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 off- shore offshore in the other Contracting State in connection with the exploration or exploitation of the seabed sea bed and subsoil sub- soil and their natural resources situated in that other State shall, sub- ject subject to paragraphs 3 and 4 of this Article4, 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 apply, where the activities are carried on for a period or periods not exceeding in the aggregate 30 days in the aggregate in any twelve months period commencing or ending in the fiscal year concernedmonth period. However, for the purposes of this paragraph: a) Where an enterprise of activities carried on by a Contracting State carrying on offshore activities in the other Contracting State person who is associated with another enterprise carrying on substantially similar offshore activities there, the former enterprise person shall be deemed 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 be carrying on all such the extent that those 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 a person shall be regarded as deemed to be associated with another enterprise person if one participates is controlled directly or indirectly in by the managementother, control or capital of the other or if the same person or persons participate both are controlled directly or indirectly in the management, control by a third person or capital of both enterprisesthird 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 seabed sea bed and subsoil 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 Contracting State of which the enterprise is a residentfirst-mentioned State. 5. 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 seabed sea bed and subsoil 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 on- ly 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 peri- ods periods not exceeding in the aggregate 30 days in any twelve-twelve month period.

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 offshore in the other Contracting State in connection with the exploration or exploitation of the seabed and or subsoil and or their natural resources situated in that other State shall, sub- ject subject 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 or periods 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 activities carried on by a Contracting State carrying on offshore activities in the other Contracting State person who is associated with another enterprise carrying person shall be regarded as carried on by the other person if the activities in question are substantially similar offshore activities there, the former enterprise same as those carried on by the first-mentioned person; b) a person 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 person if one participates is controlled directly or indirectly in by the managementother, control or capital of the other or if the same person or persons participate both are controlled directly or indirectly in the management, control by a third person or capital of both enterprisesthird persons. 4. Profits derived by a person who is 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 or subsoil and or 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 residentthat State. 5. a) Subject to sub-paragraph b) 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 or subsoil and or their natural resources situated in the other Contracting 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 on- ly 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 provided that the employment is carried on for a period or peri- ods periods not exceeding in the aggregate 30 days in any twelve-twelve- month periodperiod commencing or ending in the fiscal year concerned. b) Salaries, wages and similar remuneration derived by a resident of a Contracting State in respect of an employment exercised aboard a ship or aircraft engaged in the transportation of supplies or personnel to or from a location, or between locations, where activities connected with the exploration or exploitation of the seabed or subsoil or their natural resources are being carried on in the other Contracting State, or in respect of an employment exercised aboard tugboats or other vessels operated auxiliary to such activities, may be taxed in the State of which the person carrying on such activities is a resident. 6. 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 or subsoil or 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 or subsoil or 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 off- shore 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, sub- ject subject 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 this Article 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 concernedperiod. However, for the purposes of this paragraph: a) Where activities carried on by an enterprise of a Contracting State carrying on offshore activities in the other Contracting State is associated with another enterprise carrying shall be regarded as carried on by the enterprise with which it is associated if the activities in question are substantially similar offshore activities there, the former enterprise same as those carried on by the last-mentioned enterprise; b) two enterprises 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 is controlled directly or indirectly in by the managementother, control or capital of the other or if the same person or persons participate both are controlled directly or indirectly in the management, control by a third person or capital of both enterprisespersons. 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. This provision shall not apply if the vessel or aircraft is operated by a permanent establishment in the sense of Article 5 of this Convention, or the activities are continued for more than 6 months in any twelve months period. 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 on- ly 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 peri- ods periods not exceeding in the aggregate 30 days in any twelve-month months period.

OFFSHORE ACTIVITIES. 1. The provisions of this Article shall apply notwithstanding any other provision of this Convention. 2. A person who is a resident An enterprise of a Contracting State and one of the States which carries on activities off- shore offshore in the other Contracting State in connection with the exploration or exploitation of the seabed sea bed and subsoil sub-soil and their natural resources situated in that other State shall, sub- ject subject to paragraphs 3 and 4 of this Article, be deemed in relation to those activities to be carrying on on, in respect of those activities, 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 this Article shall not apply where the activities referred to therein are carried on in the other State for a period or periods not exceeding in the aggregate 30 days in the aggregate in any twelve months period commencing or ending in the fiscal year concerned12 months’ period. However, for For the purposes of this paragraph: a) Where a. where an enterprise of a Contracting State carrying on offshore activities referred to in paragraph 2 of this Article 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 except to the exception of extent that those activities which are carried on at the same time as its own activities; b) An 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 one of the States 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 sea bed and subsoil sub-soil and their natural resources are being carried on in a Contracting Stateone of the States, or from the operation of tugboats and other vessels auxiliary to such activities, shall be taxable only in the Contracting State in which the place of which effective management of the enterprise is a residentsituated. 5. a) a. Subject to sub-paragraph b) b of this paragraph, salaries, wages and other similar remuneration derived by a resident of a Contracting State one of the States in respect of an employment connected with the exploration or exploitation of the seabed sea bed and subsoil sub-soil and their natural resources situated in the other Contracting State may, to the extent that the duties are performed employment is exercised offshore in that other State, be taxed in that other State. However, such remuneration shall be taxable on- ly in the first-mentioned State if provided that the employment is carried on exercised offshore for an employer who is not a resident of the other State and for a period or peri- ods not periods exceeding in the aggregate 30 days in any twelve-month 12 months’ period.

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 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, sub- ject subject 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 term «activities» in paragraph 2 shall be deemed to include the bare-boat leasing of drilling rigs or similar equipment. 4. 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 concernedmonth period. However, for the purposes of this paragraph: a) Where a. activities carried on by an enterprise of a Contracting State carrying on offshore activities in the other Contracting State is associated with another enterprise carrying shall be regarded as carried on by the enterprise with which it is associated if the activities in question are substantially similar offshore activities there, the former enterprise same as those carried on by the last-mentioned enterprise; b. two enterprises 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 is controlled directly or indirectly in by the managementother, control or capital of the other or if the same person or persons participate both are controlled directly or indirectly in the management, control by a third person or capital of both enterprisespersons. 45. 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) 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 on- ly 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 peri- ods periods not exceeding in the aggregate 30 days in any twelve-twelve month period. b. Salaries, wages and similar remuneration derived by a resident of a Contracting State 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 seabed and subsoil and their natural resources are being carried on in a Contracting State, or in respect of an employment exercised aboard tugboats or other vessels operated auxiliary to such activities, shall be taxable only in the Contracting State of which the enterprise is a resident. 7. 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 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 off- shore offshore in the other Contracting State in connection with the exploration or exploitation of the seabed sea bed and subsoil sub-soil and their natural resources situated in that other State shall, sub- ject subject to paragraphs 3 and 4 of this Article4, 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 or periods not exceeding in the aggregate 30 days in the aggregate in any twelve months period commencing or ending in the fiscal year concernedtwelve-month period. However, for the purposes of this paragraph: a) Where an enterprise of activities carried on by a Contracting State carrying on offshore activities in the other Contracting State person who is associated with another enterprise carrying person shall be regarded as carried on by the other person if the activities in question are substantially similar offshore activities there, the former enterprise same as those carried on by the first-mentioned person. b) a person 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 person if one participates is controlled directly or indirectly in by the managementother, control or capital of the other or if the same person or persons participate both are controlled directly or indirectly in the management, control by a third person or capital of both enterprisesthird 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 seabed sea bed and subsoil 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 Contracting State of which the enterprise is a residentfirst-mentioned State. 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 sea bed 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 on- ly 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 peri- ods periods not exceeding in the aggregate 30 days in any twelve-month period.

OFFSHORE ACTIVITIES. 1. The provisions of this Article shall apply notwithstanding any other provision of this the Convention. 2. A person who is In this Article the term "offshore activities" means activities which are carried on offshore in a resident of a Contracting State and carries on activities off- shore in the other Contracting State in connection with the exploration exploration, exploitation or exploitation extraction of the seabed and subsoil and their natural resources situated in that State. 3. An enterprise of a Contracting State which carries on offshore activities in the other Contracting State shall, sub- ject subject to paragraphs 3 4 and 4 of this Article5, 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. 34. The provisions of paragraph 2 and sub-paragraph b) of paragraph 6 3 shall not apply where the offshore activities are carried on in the other Contracting State for a period or periods not exceeding in the aggregate 30 days in the aggregate in any twelve months twelve-month period commencing beginning or ending in the fiscal year concerned. However, for For the purposes of this paragraph: a) Where 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 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. 45. Profits derived by a resident of a Contracting State from from: a) the transportation transportation, in connection with offshore activities, of supplies or personnel by ship or aircraft to a location, or between locations, places where such activities are being carried on; or b) the operation of ships for towing or anchor handling in connection with such activities; shall be taxable only in that State. 6. Income derived by a resident of a Contracting State from exploration, exploitation or extraction rights and gains derived by a resident of a Contracting State from the exploration alienation of such rights or from the alienation of: a) property situated in the other Contracting State and used in connection with offshore activities carried on in that other State; or b) 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, exploitation or extraction rights" means rights to assets to be produced by the exploration, exploitation or extraction of the seabed and subsoil and their natural resources are being carried on in a Contracting the other State, including rights to interests in or from to the operation benefit of tugboats and other vessels auxiliary to such activities, shall be taxable only in the Contracting State of which the enterprise is a residentassets. 57. a) Subject to sub-paragraph b) 8 of this paragraphArticle, salaries, wages and similar remuneration derived by a resident of a one of the Contracting State in respect of States from an employment connected with the exploration or exploitation of the seabed and subsoil and their natural resources situated offshore 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. However, such remuneration shall be taxable on- ly 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 peri- ods not exceeding in the aggregate 30 days in any twelve-month period.

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 offshore 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 subject 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 or periods not exceeding 30 days in the aggregate in any twelve months month period commencing or ending in the fiscal year concerned. However, for the purposes of this paragraph: a) Where an enterprise of activities carried on by a Contracting State carrying on offshore activities in the other Contracting State person who is associated with another enterprise carrying person shall be regarded as carried on by the other person if the activities in question are substantially similar offshore activities there, the former enterprise same as those carried on by the first-mentioned person; b) a person 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 person if one participates is controlled directly or indirectly in by the managementother, control or capital of the other or if the same person or persons participate both are controlled directly or indirectly in the management, control by a third person or capital of both enterprisespersons. 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, salariesSalaries, wages and similar other 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 on- ly in the first-mentioned State if provided that the employment offshore is carried on offshore for an employer who is not a resident of the other State and for a period or peri- ods not exceeding in the aggregate at least 30 days in any twelvetwelve month period commencing or ending in the fiscal year concerned. 5. Gains derived by a resident of a Contracting State from the alienation of: a) rights relating to exploration or exploitation of the seabed and subsoil and their natural resources situated in the other Contracting State on any interest therein; or b) property situated in the other Contracting State and used in connection with such exploration or exploitation in that State; or c) shares deriving the greater part of their value directly or indirectly from rights and property referred to in sub-month periodparagraphs a) and b), may be taxed in that other State.

OFFSHORE ACTIVITIES. 1. The provisions of this Article shall apply notwithstanding any other provision 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 off- shore offshore in the other Contracting State in connection with the exploration or exploitation of the seabed sea bed and subsoil sub- soil and their natural resources situated in that other State shall, sub- ject subject 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 this Article shall not apply apply, where the activities are carried on for a period or periods not exceeding in the aggregate 30 days in the aggregate in any twelve months period commencing or ending in the fiscal year concernedtwelve-month period. However, for the purposes of this paragraph: a) Where an enterprise of activities carried on by a Contracting State carrying on offshore activities in the other Contracting State person who is associated with another enterprise carrying person shall be regarded as carried on by the other person if the activities in question are substantially similar offshore activities there, the former enterprise same as those carried on by the first-mentioned person; b) a person 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 person if one participates is controlled directly or indirectly in by the managementother, control or capital of the other or if the same person or persons participate both are controlled directly or indirectly in the management, control by a third person or capital of both enterprisesthird 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 seabed sea bed and subsoil 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 Contracting State of which the enterprise is a residentfirst-mentioned State. 5. 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 seabed sea bed and subsoil 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 on- ly 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 peri- ods periods not exceeding in the aggregate 30 days in any twelve-month period. b) Salaries, wages and other similar remuneration derived by a resident of a Contracting State 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 sea bed and sub-soil and their natural resources are being carried on in a Contracting State, or in respect of an employment exercised aboard tugboats or other vessels operated auxiliary to such activities, may be taxed in the Contracting State of which the employer is a resident. 6. 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 sea bed and sub-soil 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 the term "exploration or exploitation rights" means rights to assets to be produced by the exploration or exploitation of the sea bed and sub-soil 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 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. 2. A person who is a resident of a Contracting State and carries In this Article the term ―offshore activities‖ means activities which are carried on activities off- shore in the other Contracting State offshore in connection with the exploration or exploitation of the seabed and its subsoil and their natural resources resources, situated in that a Contracting State. 3. An enterprise of a Contracting State which carries on offshore activities in the other Contracting State shall, sub- ject subject to paragraphs 3 and paragraph 4 of this Article, be deemed in relation to those activities to be carrying on on, in respect of those activities, 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 , unless the offshore activities in question are carried on in the other State for a period or periods not exceeding in the aggregate 30 days in the aggregate in any twelve months period commencing or ending in the fiscal year concernedof 12 months. However, for For the purposes of this paragraph: (a) Where 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 and that other enterprise continues, as part of the same project, the same offshore activities therethat are or were being carried on by the firstmentioned enterprise, and the former aforementioned activities carried on by both enterprises – when added together – exceed a period of 30 days, then each enterprise shall be deemed to be carrying on all such its activities of the latter enterprise, with the exception of activities which are carried on at the same time as its own activitiesfor a period exceeding 30 days in a 12 month period; (b) An an enterprise shall be regarded as associated with another enterprise if one participates holds directly or indirectly in at least one third of the management, control or capital of the other enterprise or if the same a person or persons participate holds directly or indirectly in at least one third of the management, control or capital of both enterprises. 4. Profits derived However, for the purposes of paragraph 3 of this Article the term ―offshore activities‖ shall be deemed not to include: (a) one or any combination of the activities mentioned in paragraph 4 of Article 5; (b) towing or anchor handling by a ships primarily designed for that purpose and any other activities performed by such ships; (c) the transport of supplies or personnel by ships or aircraft in international traffic. 5. A resident of a Contracting State from the transportation of supplies or personnel to a location, or between locations, where who carries on offshore activities in connection with the exploration or exploitation of the seabed and subsoil and their natural resources are being carried on in a other Contracting State, which consist of professional services or from the operation other activities of tugboats and other vessels auxiliary to such activitiesan independent character, shall be taxable only deemed to be performing those activities from a permanent establishment in the other Contracting State if the offshore activities in question last for a continuous period of which the enterprise is a resident30 days or more. 56. a) Subject to sub-paragraph b) of this paragraph, salariesSalaries, 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 seabed and subsoil and their natural resources situated offshore activities carried on through a permanent establishment in the other Contracting State may, to the extent that the duties are performed employment is exercised offshore in that other State, be taxed in that other State. 7. HoweverWhere documentary evidence is produced that tax has been paid in South Africa on the items of income which may be taxed in South Africa according to Article 7 in connection with respectively paragraph 3 and paragraph 5 of this Article, such remuneration and to paragraph 6 of this Article, the Netherlands shall allow a reduction of its tax which shall be taxable on- ly computed in conformity with the first-mentioned State if the employment is carried on offshore for an employer who is not a resident rules laid down in paragraph 2 of the other State and for a period or peri- ods not exceeding in the aggregate 30 days in any twelve-month periodArticle 23.

OFFSHORE ACTIVITIES. 1. The provisions of this Article shall apply notwithstanding any other provision 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 off- shore offshore in the other Contracting State in connection with the exploration or exploitation of the seabed sea bed and subsoil sub- soil and their natural resources situated in that other State shall, sub- ject subject to paragraphs 3 and 4 of this Article4, be deemed in relation to those activities to be carrying on business in that other State through a permanent establishment or a fixed base situated therein. 3. The provisions of paragraph 2 and sub-paragraph b) of paragraph 6 shall not apply apply, where the activities are carried on for a period or periods not exceeding in the aggregate 30 days in the aggregate in any twelve months period commencing or ending in the fiscal year concernedtwelve-month period. However, for the purposes of this paragraph: a) Where an enterprise of activities carried on by a Contracting State carrying on offshore activities in the other Contracting State person who is associated with another enterprise carrying on substantially similar offshore activities there, the former enterprise person shall be deemed 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 be carrying on all such the extent that those 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 a person shall be regarded as deemed to be associated with another enterprise person if one participates is controlled directly or indirectly in by the managementother, control or capital of the other or if the same person or persons participate both are controlled directly or indirectly in the management, control by a third person or capital of both enterprisesthird persons. 4. Profits derived However, the provisions of this Article shall not apply to: a) one or any combination of the activities mentioned in paragraph 4 of Article 5 (Permanent Establishment); b) towing or anchor handling by a resident of a Contracting State from ships primarily designed for that purpose and any other activities performed by such ships; or c) the transportation transport of supplies or personnel to a location, by ships or between locations, where activities aircraft 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 residentinternational traffic. 5. a) Subject to sub-paragraph subparagraph 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 sea bed and subsoil 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 on- ly 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 peri- ods periods not exceeding in the aggregate 30 days in any twelve-month period.

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 offshore in the other Contracting State in connection with the exploration or exploitation of the seabed sea bed and subsoil sub- soil and their natural resources situated in that other State shall, sub- ject subject to paragraphs 3 and 4 of this Article4, 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 apply, where the activities are carried on for a period or periods not exceeding in the aggregate 30 days in the aggregate in any twelve months period commencing or ending in the fiscal year concernedtwelve-month period. However, for the purposes of this paragraph: a) Where an enterprise of activities carried on by a Contracting State carrying on offshore activities in the other Contracting State person who is associated with another enterprise carrying person shall be regarded as carried on by the other person if the activities in question are substantially similar offshore activities there, the former enterprise same as those carried on by the first-mentioned person; b) a person 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 person if one participates is controlled directly or indirectly in by the managementother, control or capital of the other or if the same person or persons participate both are controlled directly or indirectly in the management, control by a third person or capital of both enterprisesthird 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 seabed sea bed and subsoil 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 Contracting State of which the enterprise is a residentfirst-mentioned State. 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 sea bed and subsoil 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 on- ly 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 peri- ods periods not exceeding in the aggregate 30 days in any twelve-month period. b) Salaries, wages and similar remuneration derived by a resident of a Contracting State 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 sea bed and sub-soil and their natural resources are being carried on in a Contracting State, or in respect of an employment exercised aboard tugboats or other vessels operated auxiliary to such activities, may be taxed in the Contracting State of which the employer is a resident. 6. 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 sea bed and sub-soil 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 the term "exploration or exploitation rights" means rights to assets to be produced by the exploration or exploitation of the sea bed and sub -soil 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 provisions of this Convention. 2. A person who is Convention where activities are carried on offshore in 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 State (in this Article referred to as "offshore activities"). 2. A person who is a resident of a Contracting State and carries on offshore activities in the other Contracting State shall, sub- ject subject to paragraphs 3 and 4 of this Article, be deemed in relation to those activities to be carrying on business such activities 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 period of twelve months period commencing or ending in the fiscal year concernedmonths. However, for the purposes of this paragraph: a) Where paragraph activities carried on by 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, within the former enterprise shall be deemed to be carrying on all such activities meaning of the latter enterprise, with the exception of activities which are carried on at the same time as its own activities; b) An enterprise Article 9 shall be regarded as carried on by the enterprise with which it is associated with another enterprise if one participates directly or indirectly in the management, control or capital of the other or if the activities in question are substantially the same person or persons participate directly or indirectly in as those carried on by the management, control or capital of both enterpriseslast-mentioned enterprise. 4. Profits derived by a resident of a Contracting State from the transportation of supplies or personnel to a location, or between locations, where offshore 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 in which the place of which effective management of the enterprise is a residentsituated. 5. (a) Subject to sub-paragraph subparagraphs (b) of this paragraphand (c), 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 offshore 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. HoweverState provided that the employment offshore is carried on for a period exceeding 30 days in the aggregate in any period of twelve months. (b) Salaries, such wages and similar remuneration derived by a resident of a Contracting State in respect of an employment, shall be taxable on- ly only in that State, provided that the first-mentioned State if the employment is carried duties are performed on offshore for behalf of an employer who from that State in connection with the utilization of petroleum reservoirs which extend across the transmedian line between the Contracting State and any other State, and provided that there is not an agreement between these two States on a joint exploitation of the reservoir, and the exploitation is performed simultaneously on both sides of the transmedian line. This provision shall, however, only come into force by a separate agreement between the competent authorities of the Contracting States. (c) Salaries, wages and similar remuneration derived by a resident of the other a Contracting State and for in respect of an employment exercised aboard a period ship or peri- ods not exceeding aircraft engaged in the aggregate 30 days transportation of supplies or personnel to a location, or between locations, where offshore activities are being carried on in any twelve-month perioda Contracting State, or in respect of an employment exercised aboard tugboats or other vessels operated auxiliary to such activities, shall be taxable only in the Contracting State in which the place of effective management of the enterprise is situated.

OFFSHORE ACTIVITIES. 1. The provisions of this Article shall apply notwithstanding any other provision of this Convention. 2. A person who is a resident An enterprise of a Contracting State and which carries on activities off- shore 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, sub- ject subject to paragraphs 3 and 4 of this Articleparagraph 3, 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 concernedperiod. However, for the purposes of this paragraph: a) Where 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 therein that other State, 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 an enterprise shall be regarded as deemed to be associated with another enterprise if one participates is controlled directly or indirectly in by the managementother, control or capital of the other or if the same person or persons participate both are controlled directly or indirectly in the management, control by a third person or capital of both enterprisespersons. 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, 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 on- ly only in the first-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 peri- ods periods not exceeding in the aggregate 30 days in any twelve-month months 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 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 off- shore offshore in the other Contracting State in connection with the exploration or exploitation of the seabed sea bed and subsoil sub- soil and their natural resources situated in that other State shall, sub- ject subject to paragraphs 3 and 4 of this Article4, 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 apply, where the activities are carried on for a period or periods not exceeding in the aggregate 30 days in the aggregate in any twelve months period commencing or ending in the fiscal year concernedtwelve-month period. However, for the purposes of this paragraph: a) Where an enterprise of activities carried on by a Contracting State carrying on offshore activities in the other Contracting State person who is associated with another enterprise carrying person shall be regarded as carried on by the other person if the activities in question are substantially similar offshore activities there, the former enterprise same as those carried on by the first-mentioned person; b) a person 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 person if one participates is controlled directly or indirectly in by the managementother, control or capital of the other or if the same person or persons participate both are controlled directly or indirectly in the management, control by a third person or capital of both enterprisesthird 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 seabed sea bed and subsoil 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 Contracting State of which the enterprise is a residentfirst-mentioned State. 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 sea bed and subsoil 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 on- ly 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 peri- ods periods not exceeding in the aggregate 30 days in any twelve-month period.

OFFSHORE ACTIVITIES. 1. The provisions of this Article shall apply notwithstanding any other provision of this Convention. 2. A person who is a resident An enterprise of a Contracting State and which carries on activities off- shore 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, sub- ject subject to paragraphs 3 and 4 of this Articleparagraph 3, 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 concernedperiod. However, for the purposes of this paragraph: a) Where 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 therein that other State, 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 an enterprise shall be regarded as deemed to be associated with another enterprise if one participates is controlled directly or indirectly in by the managementother, control or capital of the other or if the same person or persons participate both are controlled directly or indirectly in the management, control by a third person or capital of both enterprisespersons. 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, 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 on- ly 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 peri- ods periods not exceeding in the aggregate 30 days in any twelve-month months 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;

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 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, sub- ject subject to paragraphs paragraph 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 Paragraph 2 of paragraph 2 and sub-paragraph b) of paragraph 6 this Article, shall not apply where to 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 paragraphfollowing activities: a) Where an enterprise of a Contracting State carrying on offshore activities in the a. towing or anchor handling by ships primarily designed for that purpose and any 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 activity performed by such activities of the latter enterprise, with the exception of activities which are carried on at the same time as its own activitiesships; b) An enterprise shall be regarded as associated with another enterprise if one participates directly or indirectly in b. 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 transport of supplies or personnel to a location, by ships or between locations, where activities aircraft 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 residentinternational traffic. 5. a) 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 on- ly 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 peri- ods periods not exceeding in the aggregate 30 days in any twelve-twelve month period. b. Salaries, wages and similar remuneration derived by a resident of a Contracting State 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 seabed and subsoil and their natural resources are being carried on in the other Contracting State, or in respect of an employment exercised aboard tugboats or other vessels operated auxiliary to such activities, may be taxed in accordance with the provisions of Article 15 of this Convention. 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 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 off- shore 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, sub- ject subject 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 concernedperiod. However, for the purposes of this paragraph: a) Where activities carried on by an enterprise of a Contracting State carrying on offshore activities in the other Contracting State is associated with another enterprise carrying shall be regarded as carried on by the enterprise with which it is associated if the activities in question are substantially similar offshore activities there, the former enterprise same as those carried on by the last-mentioned enterprise; b) two enterprises 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 is controlled directly or indirectly in by the managementother, control or capital of the other or if the same person or persons participate both are controlled directly or indirectly in the management, control by a third person or capital of both enterprisespersons. 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. a5.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 on- ly 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 peri- ods periods not exceeding in the aggregate 30 days in any twelve-month months period.

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 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, sub- ject subject 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, and be taxed according to Article 7 or Article 14 as the case may be. 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 concernedtwelve-month period. However, for the purposes of this paragraph: a) Where a. activities carried on by an enterprise of a Contracting State carrying on offshore activities in the other Contracting State is associated with another enterprise carrying shall be regarded as carried on by the enterprise with which it is associated if the activities in question are substantially similar offshore activities there, the former enterprise same as those carried on by the last-mentioned enterprise; b. two enterprises 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 is controlled directly or indirectly in by the managementother, control or capital of the other or if the same person or persons participate both are controlled directly or indirectly in the management, control by a third person or capital of both enterprisespersons. 4. Profits derived by a resident an enterprise 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 shall, subject to Article 8, be taxable only in the Contracting State of which the enterprise is a resident. Except where such vessel or aircraft is operated in international traffic, the provisions of this paragraph shall not apply if the vessel or aircraft is operated by a permanent establishment in the sense of Article 5. In this case the provisions of Article 7 shall apply. 5. a) 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 on- ly 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 provided that the employment is carried on for a period or peri- ods periods not exceeding in the aggregate 30 days in any twelve-twelve- month period. b. Salaries, wages and similar remuneration derived by a resident of a Contracting State 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 seabed and subsoil and their natural resources are being carried on in the other Contracting State, or in respect of an employment exercised aboard tugboats or other vessels operated auxiliary to such activities, shall be taxable according to Article 15. 6. 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 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 An enterprise of a Contracting State and which carries on any offshore activities off- shore in the other Contracting State in connection with the exploration or exploitation of the seabed and or subsoil and or their natural resources situated in that other State shall, sub- ject subject 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 offshore activities are carried on for a period not exceeding 30 days in the aggregate in any twelve months month period commencing or ending in the fiscal year concerned. However, for the purposes of this paragraph: a) Where a. activities carried on by an enterprise of a Contracting State carrying on offshore activities in the other Contracting State is associated with another enterprise carrying shall be regarded as carried on by the enterprise with which it is associated if the activities in question are substantially similar offshore activities there, the former enterprise same as those carried on there by the last-mentioned enterprise; b. two enterprises 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;associated if: b) An i. 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 another enterprise, or ii. the same person or persons participate directly or indirectly in the management, control or capital of both enterprises. 4. Profits derived by a resident an enterprise of a Contracting State from the transportation of supplies or personnel to a location, or between locations, where offshore activities in connection with the exploration or exploitation of the seabed and or subsoil and or their natural resources are being carried on in a the other Contracting State, or from the operation of tugboats and or other vessels auxiliary to such offshore activities, shall be taxable only in the Contracting State of which the enterprise is a resident. 5. a) 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 or subsoil and or 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 on- ly only in the first-mentioned State if the employment is carried on offshore in the other State for an employer who is not a resident of the that other State and provided that the employment is carried on there for a period or peri- ods periods not exceeding in the aggregate 30 days in any twelve-twelve month periodperiod commencing or ending in the fiscal year concerned. b. Salaries, wages and similar remuneration derived by a resident of a Contracting State 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 offshore activities in connection with the exploration or exploitation of the seabed or subsoil or their natural resources are being carried on in the other Contracting State, or in respect of an employment exercised aboard tugboats or other vessels operated auxiliary to such activities, shall be taxable only in the State of which the recipient is a resident, unless the employer is a resident of the other State. In such case the income may be taxed in that other State. 6. 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 or subsoil or 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 or subsoil or 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 off- shore 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, sub- ject subject 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, and be taxed according to Article 7 or Article 14 as the case may be. 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 concernedtwelve-month period. However, for the purposes of this paragraph: (a) Where activities carried on by an enterprise of a Contracting State carrying on offshore activities in the other Contracting State is associated with another enterprise carrying shall be regarded as carried on by the enterprise with which it is associated if the activities in question are substantially similar offshore activities there, the former enterprise same as those carried on by the last- mentioned enterprise; (b) two enterprises 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 is controlled directly or indirectly in by the managementother, control or capital of the other or if the same person or persons participate both are controlled directly or indirectly in the management, control by a third person or capital of both enterprisespersons. 4. Profits derived by a resident an enterprise 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 shall, subject to Article 8, be taxable only in the Contracting State of which the enterprise is a resident. Except where such vessel or aircraft is operated in international traffic, the provisions of this paragraph shall not apply if the vessel or aircraft is operated by a permanent establishment in the sense of Article 5. In this case the provisions of Article 7 shall apply. 5. 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 on- ly 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 provided that the employment is carried on for a period or peri- ods periods not exceeding in the aggregate 30 days in any twelve-month period.

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 offshore 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 subject 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 or periods not exceeding 30 days in the aggregate in any twelve months month period commencing or ending in the fiscal year concerned. However, for the purposes of this paragraph: a) Where an enterprise of activities carried on by a Contracting State carrying on offshore activities in the other Contracting State person who is associated with another enterprise carrying person shall be regarded as carried on by the other person if the activities in question are substantially similar offshore activities there, the former enterprise same as those carried on by the first-mentioned person; b) a person 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 person if one participates is controlled directly or indirectly in by the managementother, control or capital of the other or if the same person or persons participate both are controlled directly or indirectly in the management, control by a third person or capital of both enterprisespersons. 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, salariesSalaries, wages and similar other 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 on- ly in the first-mentioned State if provided that the employment offshore is carried on offshore for an employer who is not a resident of the other State and for a period or peri- ods not exceeding in the aggregate at least 30 days in any twelvetwelve month period commencing or ending in the fiscal year concerned. 5. Gains derived by a resident of a Contracting State from the alienation of: a) rights relating to exploration or exploitation of the seabed and subsoil and their natural resources situated in the other Contracting State on any interest therein, or b) property situated in the other Contracting State and used in connection with such exploration or exploitation in that State, or c) shares deriving the greater part of their value directly or indirectly from rights and property referred to in sub-month periodparagraphs a) and b), may be taxed in that other State.

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 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, sub- ject subject 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 or periods 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 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: (i) 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 an enterprise of the other or if Contracting State, or (ii) 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 on- ly 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 peri- ods periods not exceeding in the aggregate 30 days in any twelve-month periodmonths period commencing or ending in the fiscal year concerned. b) Salaries, wages and similar remuneration derived by a resident of a Contracting State 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 seabed and subsoil and their natural resources are being carried on in the other Contracting State, or in respect of an employment exercised aboard tugboats or other vessels operated auxiliary to such activities, may be taxed in the Contracting State of which the enterprise carrying on such activities is a resident. 6. 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 or subsoil or 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.