Common use of OFFSHORE ACTIVITIES Clause in Contracts

OFFSHORE ACTIVITIES. 1. The provisions of this Article shall apply notwithstanding any other provision of this Agreement. 2. A person who is a resident of Singapore and carries on activities offshore in Norway in connection with the exploration or exploitation of the seabed and subsoil and their natural resources situated in Norway shall, subject to paragraphs 3 and 4 of this Article, be deemed in relation to those activities to be carrying on business in Norway through a permanent establishment or fixed base situated therein. 3. The provisions of paragraph 2 shall not apply where the activities are carried on for a period not exceeding 30 days in the aggregate in any twelve month period. However, for the purposes of this paragraph: (a) activities carried on by an enterprise associated with another enterprise shall be regarded as carried on by the enterprise with which it is associated if the activities in question are substantially the same as those carried on by the last-mentioned enterprise; (b) two enterprises shall be deemed to be associated if one is controlled directly or indirectly by the other, or both are controlled directly or indirectly by a third person or persons. 4. Profits derived by a resident of Singapore from the transportation of supplies or personnel to a location, or between locations, where activities in connection with the exploration or exploitation of the seabed and subsoil and their natural resources are being carried on in Norway, or from the operation of tugboats and other vessels auxiliary to such activities, shall be taxable only in Singapore. (a) Subject to sub-paragraph (b) of this paragraph, salaries, wages and similar remuneration derived by a resident of Singapore in respect of an employment connected with the exploration or exploitation of the seabed and subsoil and their natural resources situated in Norway may, to the extent that the duties are performed offshore in Norway, be taxed in Norway. However, such remuneration shall be taxable only in Singapore if the employment is carried on offshore for an employer who is not a resident of Norway and for a period or periods not exceeding in the aggregate 30 days in any twelve-month period. (b) Salaries, wages and similar remuneration derived by a resident of Singapore in respect of an employment exercised aboard a ship or aircraft engaged in the transportation of supplies or personnel to a location, or between locations, where activities connected with the exploration or exploitation of the seabed and subsoil and their natural resources are being carried on in Norway, or in respect of an employment exercised aboard tugboats or other vessels operated auxiliary to such activities, shall be taxable only in Singapore. 6. Gains derived by a resident of Singapore from the alienation of: (a) exploration or exploitation rights; or (b) property situated in Norway and used in connection with the exploration or exploitation of the seabed and subsoil and their natural resources situated in Norway; or (c) shares, other than shares traded on a recognised Stock Exchange, 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 Norway. 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 Norway, including rights to interests in or to the benefit of such assets.

OFFSHORE ACTIVITIES. 1. The provisions of this Article shall apply have effect notwithstanding any other provision the provisions of this AgreementConvention. 2. A person who is a resident of Singapore a Contracting State and carries on activities offshore in Norway 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 Norway that other State shall, subject to paragraphs 3 and 4 of this Article4, be deemed in relation to those activities to be carrying on business in Norway that other State through a permanent establishment or fixed base situated therein. 3. The provisions of paragraph 2 shall not apply where the activities are carried on for a period not exceeding 30 days in the aggregate in any twelve month period. However, for the purposes of this paragraph: (a) activities carried on by an enterprise associated with another enterprise shall be regarded as carried on by the enterprise with which it is associated if the activities in question are substantially the same as those carried on by the last-last- mentioned enterprise; (b) two enterprises shall be deemed to be associated if one is controlled directly or indirectly by the other, or both are controlled directly or indirectly by a third person or persons. 4. Profits derived by a resident of Singapore a Contracting State from the transportation of supplies or personnel personal 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 Norwaya Contracting State, or from the operation of tugboats and other vessels auxiliary to such activities, shall be taxable only in Singaporethat State. (a) Subject to sub-paragraph (b) of this paragraph, salaries5. Salaries, wages and similar remuneration derived by a resident of Singapore 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 Norway the other Contracting State may, to the extent that the duties are performed offshore in Norwaythat other State, be taxed in Norway. However, such remuneration shall be taxable only in Singapore if that other State provided that the employment offshore is carried on offshore for an employer who is not a resident of Norway and for a period or periods not exceeding 30 days in the aggregate 30 days in any twelve-twelve month period. (b) Salaries, wages and similar remuneration derived by a resident of Singapore in respect of an employment exercised aboard a ship or aircraft engaged in the transportation of supplies or personnel to a location, or between locations, where activities connected with the exploration or exploitation of the seabed and subsoil and their natural resources are being carried on in Norway, or in respect of an employment exercised aboard tugboats or other vessels operated auxiliary to such activities, shall be taxable only in Singapore. 6. Gains derived by a resident of Singapore from the alienation of: (a) exploration or exploitation rights; or (b) property situated in Norway and used in connection with the exploration or exploitation of the seabed and subsoil and their natural resources situated in Norway; or (c) shares, other than shares traded on a recognised Stock Exchange, 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 Norway. 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 Norway, 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 Agreement. 2. A person who is a resident of Singapore and carries on activities offshore in Norway in connection with the exploration or exploitation of the seabed and subsoil and their natural resources situated in Norway shall, subject to paragraphs 3 and 4 of this Article, be deemed in relation to those activities to be carrying on business in Norway through a permanent establishment or fixed base situated therein. 3. The provisions of paragraph 2 shall not apply where the activities are carried on for a period not exceeding 30 days in the aggregate in any twelve month period. However, for the purposes of this paragraph: (a) a. activities carried on by an enterprise associated with another enterprise shall be regarded as carried on by the enterprise with which it is associated if the activities in question are substantially the same as those carried on by the last-mentioned enterprise; (b) b. two enterprises shall be deemed to be associated if one is controlled directly or indirectly by the other, or both are controlled directly or indirectly by a third person or persons. 4. Profits derived by a resident of Singapore from the transportation of supplies or personnel to a location, or between locations, where activities in connection with the exploration or exploitation of the seabed and subsoil and their natural resources are being carried on in Norway, or from the operation of tugboats and other vessels auxiliary to such activities, shall be taxable only in Singapore. (a) a. Subject to sub-paragraph (b) of this paragraph, salaries, wages and similar remuneration derived by a resident of Singapore in respect of an employment connected with the exploration or exploitation of the seabed and subsoil and their natural resources situated in Norway may, to the extent that the duties are performed offshore in Norway, be taxed in Norway. However, such remuneration shall be taxable only in Singapore if the employment is carried on offshore for an employer who is not a resident of Norway and for a period or periods not exceeding in the aggregate 30 days in any twelve-month period. (b) b. Salaries, wages and similar remuneration derived by a resident of Singapore in respect of an employment exercised aboard a ship or aircraft engaged in the transportation of supplies or personnel to a location, or between locations, where activities connected with the exploration or exploitation of the seabed and subsoil and their natural resources are being carried on in Norway, or in respect of an employment exercised aboard tugboats or other vessels operated auxiliary to such activities, shall be taxable only in Singapore. 6. Gains derived by a resident of Singapore from the alienation of: (a) a. exploration or exploitation rights; or (b) b. property situated in Norway and used in connection with the exploration or exploitation of the seabed and subsoil and their natural resources situated in Norway; or (c) c. shares, other than shares traded on a recognised Stock Exchange, 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 Norway. 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 Norway, including rights to interests in or to the benefit of such assets.