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HMRC internal manual

Oil Taxation Manual

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Non-Residents Working on the UK Continental Shelf: Double Taxation Agreements - Treaties with an Offshore Activities Article - Example 2

Example 2 - USA

The effect of Article 21 of the new UK/USA treaty (SI2002\2848) is broadly similar to the Norwegian treaty in that activities carried on offshore in connection with the exploration or exploitation of UK natural resources are deemed to be carried on through a UK permanent establishment. This new treaty applies from 1 April 2003 for CT purposes.

However the de minimis time rule is different in that it only applies to exploration activities. Consequently exploitation activities cannot obtain the benefit of the 30 day time rule and are taxable from day 1.