Offshore activities

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....th the exploration or exploitation of the sea-bed and sub-soil and their natural resources situated in that other State shall, subject to paragraphs (3) and (4) of this article, be deemed in relation to those activities to be carrying on business in that other State through a permanent establishment or fixed base situated therein. 3. The provisions of paragraph (2) shall not apply where the act....

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....the exploration or exploitation of the sea-bed and subsoil and their natural resources are being carried on in a Contracting State, or from the operation of tugboats and other vessels auxiliary to such activities, shall be taxable only in the Contracting State in which the place of effective management of the enterprise is situated. Notwithstanding the provisions of this paragraph, profits deri....

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....and their natural resources situated in the other Contracting State shall, to the extent that the duties are performed offshore in that other State, be taxable only in that other State provided that the employment offshore is carried on for a period exceeding 30 days in the aggregate in any 12 months period. (b) Salaries, wages and similar remuneration derived by a resident of the Contracting S....