Replaced by new DTA, which applies in UK from 1st April 2003 for
CT, 6th April 2003 for IT and 1st January 2004 for PRT. For US
withholding taxes it applies from 1st May 2003 and for other US
taxes from 1st January 2004. See DT19939L.
(1) Notwithstanding the provisions of Article 5 (Permanent
establishment) and Article 14 (Independent personal services), a
person who is a resident of a Contracting State and carries on
activities in the other Contracting State in connection with the
exploration or exploitation of the seabed and sub-soil and their
natural resources situated in that other Contracting State shall be
deemed to be carrying on in respect of those activities a business
in that other Contracting State through a permanent establishment
or fixed base situated therein.
(2) The provisions of paragraph (1) shall not apply where
the activities are carried on for a period not exceeding 30 days in
aggregate in any 12 month period. However, for the purpose of this
paragraph, activities carried on by an enterprise related to
another enterprise shall be regarded as carried on by the
enterprise to which it is related if the activities in question are
substantially the same as those carried on by the last-mentioned
enterprise.
(3) The provisions of Article 8 (Shipping and air transport)
shall not apply to a drilling rig or any vessel the principal
function of which is the performance of activities other than the
transportation of goods or passengers.
