OFFSHORE ACTIVITIES. 1. The provisions of this Article shall apply notwithstanding any other provisions of this Convention. However, this Article shall not apply where offshore activities of a person constitute for that person a permanent establishment under the provisions of Article 5 or a fixed base under the provisions of Article 14.
Appears in 18 contracts
OFFSHORE ACTIVITIES. 1. The provisions of this Article shall apply notwithstanding any other provisions of this Convention. However, this Article shall not apply where offshore activities of a person constitute for that person a permanent establishment under the provisions of Article 5 or a fixed base under the provisions of Article 145.
Appears in 4 contracts
Samples: cacollege.co.za, Agreement, Agreement
OFFSHORE ACTIVITIES. 1. The provisions of this Article shall apply notwithstanding any other provisions of this ConventionAgreement. However, this Article shall not apply where offshore activities of a person constitute for that person a permanent establishment under the provisions of Article 5 or a fixed base under the provisions of Article 14.
Appears in 3 contracts
Samples: Agreement, Agreement, internationaltaxtreaty.com
OFFSHORE ACTIVITIES. 1. The provisions of this Article shall apply notwithstanding any other provisions of this ConventionAgreement. However, this Article shall not apply where offshore activities of a person constitute for that person a permanent establishment under the provisions of Article 5 or a fixed base under the provisions of Article 145.
Appears in 2 contracts
Samples: Agreement, internationaltaxtreaty.com
OFFSHORE ACTIVITIES. 1. The provisions of this Article shall apply notwithstanding any other provisions of this Convention. However, this Article shall not apply where offshore activities of a person constitute for that person a permanent establishment under the provisions of Article 5 (Permanent establishment) or a fixed base under the provisions of Article 1414 (Independent personal services).
Appears in 1 contract
Samples: internationaltaxtreaty.com
OFFSHORE ACTIVITIES. 1. The provisions of this Article shall apply notwithstanding any other provisions of this Convention. However, this Article shall not apply where offshore activities of a person constitute for that person a permanent establishment under the provisions of Article 5 of this Convention or a fixed base under the provisions of Article 1414 of this Convention.
Appears in 1 contract
Samples: internationaltaxtreaty.com