OFFSHORE ACTIVITIES. 1. The provisions of this Article shall apply notwithstanding any other provisions of this Convention. However, this Article shall not apply where offshore activities of a person constitute for that person a permanent establishment under the provisions of Article 5 or a fixed base under the provisions of Article 14. 2. In this Article the term “offshore activities” means activities which are carried on offshore in connection with the exploration or exploitation of the sea bed and its sub-soil and their natural resources, situated in a Contracting State.
Appears in 9 contracts
Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
OFFSHORE ACTIVITIES. 1. The provisions of this Article shall apply notwithstanding any other provisions of this Convention. However, this Article shall not apply where offshore activities of a person constitute for that person a permanent establishment under the provisions of Article 5 or a fixed base under the provisions of Article 14.
2. In this Article the term “"offshore activities” " means activities which are carried on offshore in connection with the exploration or exploitation of the sea bed and its sub-soil and their natural resources, situated in a Contracting State.
Appears in 5 contracts
Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
OFFSHORE ACTIVITIES. 1. The provisions of this Article shall apply notwithstanding any other provisions of this ConventionAgreement. However, this Article shall not apply where offshore activities of a person constitute for that person a permanent establishment under the provisions of Article 5 or a fixed base under the provisions of Article 14.
2. In this Article the term “offshore activities” means activities which are carried on offshore in connection with the exploration exploration, extraction or exploitation of the sea bed seabed and its sub-soil subsoil and their natural resources, situated in a Contracting State.
Appears in 3 contracts
Samples: Agreement for the Avoidance of Double Taxation, Double Taxation Agreement, Income Tax Agreement
OFFSHORE ACTIVITIES. 1. The provisions of this Article shall apply notwithstanding any other provisions of this Convention. However, this Article shall not apply where offshore activities of a person constitute for that person a permanent establishment under the provisions of Article 5 or a fixed base under the provisions of Article 14.
2. In this Article the term “offshore activities” means activities which are carried on offshore in connection with the exploration or exploitation of the sea bed and its sub-soil subsoil and their natural resources, situated in a Contracting State.
Appears in 3 contracts
Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
OFFSHORE ACTIVITIES. 1. The provisions of this Article shall apply notwithstanding any other provisions of this Convention. However, this Article shall not apply where offshore activities of a person constitute for that person a permanent establishment under the provisions of Article 5 or a fixed base under the provisions of Article 145.
2. In this Article the term “offshore activities” means activities which are carried on offshore in connection with the exploration or exploitation of the sea bed seabed and its sub-soil subsoil and their natural resources, situated in a Contracting State.
Appears in 3 contracts
Samples: Double Taxation Agreement, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
OFFSHORE ACTIVITIES. 1. The provisions of this Article shall apply notwithstanding any other provisions of this Convention. However, this Article shall not apply where offshore activities of a person constitute for that person a permanent establishment under the provisions of Article 5 or a fixed base under the provisions of Article 14.
2. In this Article the term “offshore activities” " means activities which are carried on offshore in connection with the exploration or exploitation of the sea bed and its sub-soil and their natural resources, situated in a Contracting State.
Appears in 2 contracts
Samples: Income and Capital Tax Convention, Income and Capital Tax Convention
OFFSHORE ACTIVITIES. 1. The provisions of this Article shall apply notwithstanding any other provisions of this Convention. However, this Article shall not apply where offshore activities of a person constitute for that person a permanent establishment under the provisions of Article 5 of this Convention or a fixed base under the provisions of Article 1414 of this Convention.
2. In this Article the term “offshore activities” means activities which are carried on offshore in connection with the exploration or exploitation of the sea bed and its sub-soil and their natural resources, situated in a Contracting State.
Appears in 1 contract
OFFSHORE ACTIVITIES. 1. The provisions of this Article shall apply notwithstanding any other provisions of this ConventionAgreement. However, this Article shall not apply where offshore activities of a person constitute for that person a permanent establishment under the provisions of Article 5 or a fixed base under the provisions of Article 14.
2. In this Article the term “offshore activities” means activities which are carried on offshore in connection with the exploration or exploitation of the sea bed and its sub-soil and their natural resources, situated in a Contracting State.
Appears in 1 contract
OFFSHORE ACTIVITIES. 1. The provisions of this Article shall apply notwithstanding any other provisions of this Convention. However, this Article shall not apply where offshore activities of a person constitute for that person a permanent establishment under the provisions of Article 5 (Permanent establishment) or a fixed base under the provisions of Article 1414 (Independent personal services).
2. In this Article the term “offshore activities” " means activities which are carried on offshore in connection with the exploration or exploitation of the sea bed and its sub-soil and their natural resources, situated in a Contracting State.
Appears in 1 contract
Samples: Income and Capital Tax Convention
OFFSHORE ACTIVITIES. 1. The provisions of this Article shall apply notwithstanding any other provisions of this ConventionAgreement. However, this Article shall not apply where offshore activities of a person constitute for that person a permanent establishment under the provisions of Article 5 or a fixed base under the provisions of Article 145.
2. In this Article the term “"offshore activities” " means activities which are carried on offshore in connection with the exploration or exploitation of the sea bed seabed and its sub-soil subsoil and their natural resources, situated in a Contracting StateParty.
Appears in 1 contract
OFFSHORE ACTIVITIES. 1. The provisions of this Article shall apply notwithstanding any other provisions of this Convention. However, this Article shall not apply where offshore activities of a person constitute for that person a permanent establishment under the provisions of Article 5 or a fixed base under the provisions of Article 14.
2. In this Article the term “offshore activities” means activities which are carried on offshore in connection with the exploration or exploitation of the sea sea-bed and its sub-soil subsoil and their natural resources, situated in a Contracting Stateone of the States.
Appears in 1 contract
OFFSHORE ACTIVITIES. 1. The provisions of this Article shall apply notwithstanding any other provisions of this ConventionAgreement. However, this Article shall not apply where offshore activities of a person constitute for that person a permanent establishment under the provisions of Article 5 or a fixed base under the provisions of Article 145.
2. In this Article the term “offshore activities” means activities which are carried on offshore in connection with the exploration or exploitation of the sea bed seabed and its sub-soil subsoil and their natural resources, situated in a Contracting StateParty.
Appears in 1 contract
Samples: Tax Agreement
OFFSHORE ACTIVITIES. 1. The provisions of this Article shall apply notwithstanding any other provisions of this Convention. However, this Article shall not apply where offshore activities of a person constitute for that person a permanent establishment under the provisions of Article 5 or a fixed base under the provisions of Article 14.
2. In this Article the term “offshore activities” means activities which are carried on offshore in connection with the exploration or exploitation of the sea bed seabed and its sub-soil subsoil and their natural resources, situated in a Contracting State.
Appears in 1 contract
OFFSHORE ACTIVITIES. 1. The provisions of this Article shall apply notwithstanding any other provisions of this ConventionAgreement. However, this Article shall not apply where offshore activities of a person constitute for that person a permanent establishment under the provisions of Article 5 or a fixed base under the provisions of Article 1415.
2. In this Article the term “offshore activities” means activities which are carried on offshore in connection with the exploration or exploitation of the sea bed and its sub-soil and their natural resources, situated in a Contracting Stateone of the two States.
Appears in 1 contract
OFFSHORE ACTIVITIES. 1. The provisions of this Article shall apply notwithstanding any other provisions of this Convention. However, this Article shall not apply where offshore activities of a person constitute for that person a permanent establishment under the provisions of Article 5 or a fixed base under the provisions of Article 145.
2. In this Article the term “offshore activities” means activities which are carried on offshore in connection with the exploration or exploitation of the sea bed and its sub-soil and their natural resources, situated in a Contracting State.
Appears in 1 contract