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HMRC internal manual

Oil Taxation Manual

Non-Residents Working on the UK Continental Shelf: Double Taxation Agreements - Treaties with an Offshore Activities Article - Example 3

Example 3 - France & Netherlands

The effect of Article 22 of the new UK/France treaty (and Article 29A of the previous treaty which applied up to and including 2009/10) (SI87\466) and Article 22A of the UK/Netherlands treaty (SI85\1997) is broadly similar 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 except for short term activities covered by the 30 day de minimis time rule and the transportation of supplies or personnel and the operation of tug boats.

Both treaties specifically deem independent personal services carried on offshore to be performed through a fixed base in the UK except for short term activities covered by the 30 day rule

The UK has negotiated a new agreement with the Netherlands as of July 2010 this is not yet in force. This new Treaty does not however contain any material changes to the offshore Articles.