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HMRC internal manual

Double Taxation Relief Manual

New Zealand: Exploration and exploitation

The agreement has specific provisions for dealing with income arising from activities carried out in connection with the exploration and exploitation of the seabed, subsoil and their natural resources namely:

  1. an enterprise of one country carrying on such activities in the other country is deemed to be carrying on business in that other country through a permanent establishment;
  2. an individual who is a resident of one country who carries on such activities consisting of professional services or other activities of an independent nature in the other country is deemed to be performing those activities from a fixed base in that other country;
  3. remuneration paid to a resident of one country from an employment exercised in the other country in connection with such activities may be taxed in that other country.