Offshore activities permanent establishment deemed for seabed exploration, with limited short stay and transport taxation exceptions. Offshore activities connected with exploration or exploitation of seabed or subsoil resources are deemed to be carried on through a permanent establishment or fixed base in the State where those activities occur, subject to a short stay thirty day aggregate exception and aggregation rules for associated enterprises. Transport and auxiliary vessel profits are taxable only in the enterprise's State of residence, although the source State may tax such operations up to fifty per cent of its domestic tax; a specified cap applies to profits taxable in India.