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HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
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Finland: Off-shore activities

Article 30A of the agreement contains provisions for the treatment of activities in connection with the exploration or exploitation of the sea bed sub-soil and their natural resources. These provide that

a) an enterprise of one country carrying on such activities in the other country is deemed to be carried on a business in the other country through a permanent establishment;

b) a resident of one country who carries on such activities in the other country consisting of professional services or other independent activities of a similar character is deemed to be performing those activities from a fixed base in that other country;

c) profits derived by a resident of one country from the operation of ships or aircraft for the purpose of transporting supplies or personnel in connection with such activity are taxable only in the country of the operator’s residence.

Refer to paragraphs (3) and (4) of Article 30 for details of certain limitations in connection with the duration of such activities;

d) earnings for duties in connection with such activities performed off-shore in one country may be taxed in that country. Refer any problems in this connection to Business and Management Services Division (Operational Systems and Support), Matheson House, Telford.