Offshore permanent establishment rules: seabed exploration activities can create taxable PE, with transport and salary exceptions.

Offshore activities linked to exploration or exploitation of the sea-bed and subsoil create a deemed permanent establishment in the State where those activities occur, subject to a short-duration exemption and aggregation rules for associated enterprises. Profits from transporting supplies or personnel and operation of auxiliary vessels are taxable only in the State of the enterprise's place of effective management, with limited additional taxing authority in the State where operations occur and a specified cap for taxation in India. Employment income for duties performed offshore is taxable in the State where duties are performed when the employment exceeds the short-duration threshold, while employment aboard transport or auxiliary vessels is taxed in the State of the place of effective management.

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