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HMRC internal manual

Double Taxation Relief Manual

DT: New Zealand: double taxation agreement, Article 6: Exploration and exploitation activities

(1) The provisions of this Article shall apply notwithstanding any other provision of this Convention where activities are carried on in connection with the exploration and exploitation of the sea-bed and subsoil and their natural resources (in this Article called `specified activities`) situated in a Contracting State.

(2) An enterprise of a Contracting State which carries on specified activities in the other Contracting State shall be deemed to be carrying on business in that other State through a permanent establishment situated therein.

(3) An individual who is a resident of a Contracting State who carries on specified activities in the other Contracting State, which consist of professional services or other activities of a independent character, shall be deemed to be performing those activities from a fixed base regularly available to him in that other State.

(4) Salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment in the other Contracting State may, to the extent that the employment is exercised in connection with specified activities in that other State, be taxed in that other State.