Offshore activities treated as permanent establishment, with distinct taxation rules for transport profits and offshore employment.

Offshore exploration or exploitation activities create a deemed business presence in the source State through a permanent establishment or fixed base, except where activities fall below an aggregate temporal threshold or are adjusted by aggregation rules for associated enterprises. Transportation and auxiliary-vessel profits are generally taxable only in the enterprise's resident State, though the source State may tax operations carried on there subject to a capped charge. Employment income for duties performed offshore is taxable in the source State, with an exception for short-term employment for nonresident employers and distinct rules for employment aboard transport or auxiliary vessels.

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