(1) The provisions of this Article shall apply notwithstanding
any other provision of this Agreement where activities (in this
Article called “relevant activities”) are carried on offshore in
connection with the exploration or exploitation of the sea bed
and subsoil and their natural resources situated in a Contracting
State.
(2) An enterprise of a Contracting State which carries on
relevant activities in the other Contracting State shall, subject to
paragraph 3 of this Article, be deemed to be carrying on
business in that other State through a permanent establishment
situated therein.
(3) The provisions of paragraph 2 shall not apply where the
activities referred to in paragraph 1 are carried on in the areas
specified in that paragraph for a period not exceeding a total of:
a) in the case of activities in connection with exploration,
90 days in any period of twelve months commencing or
ending in the fiscal year concerned; and
b) in the case of activities in connection with exploitation,
30 days in any period of twelve months commencing or
ending in the fiscal year concerned.
(4) Salaries, wages and similar remuneration derived by a
resident of a Contracting State in respect of an employment
connected with relevant activities in the other Contracting State
may, to the extent that the duties are performed offshore in that
other State, be taxed in that other State.
(5) Gains derived by a resident of a Contracting State from the
alienation of:
a) exploration or exploitation rights; or
b) shares (or comparable instruments) deriving their value or the
greater part of their value directly or indirectly from such
rights,
may be taxed in that other State. In this paragraph “exploration or
exploitation rights” mean rights to assets to be produced by the
exploration or exploitation of the seabed or subsoil or their nat-
ural resources in the other Contracting State, including rights to
interests in or to the benefit of such assets.
de-ireland-2011-base | BGBl. 2011 II S. 1042 (consent law); S. 1043–1067 (agreement, protocol and joint declaration) | signed 2011-03-30 | published 2011-11-07 | Signed: 2011-03-30 | Gazette publication: 2011-11-07
Source form
Official original2011 PDF; reader from proved font-CMap-only derivative, not the original facsimile
Source scope
Original consent law, DE/EN convention, integral protocol and joint declaration; not amended/current law
Retrieved
2026-10-02
Text and language scope
Unreviewed machine transcription. Original 2011 publication only, not a verified current-law consolidation. No qualified human wording, legal, alignment, indexing, deployment or publication approval. Noindex preview only; noindex is not access control. Published treaty languages: German and English. Original closing on physical page 21 declares both texts equally authoritative. Both bodies come exclusively from the original 2011 PDF. No third language, translation or cross-language paragraph alignment is inferred. English interface; legal source containers carry their own language. Source-proved reversible blank-glyph CMap correction only; no OCR, translation, wording/spacing/hyphen repair. Native spans and coordinate gaps retained; all26 original/derivative renders identical. Law, preamble, execution, signatures, integral protocol and joint declaration: /review/de-ireland-2011-base/. Source links indicate pages, not independently approved paragraph alignment.
Review status
Pending independent qualified human wording, completeness, currentness, alignment and rendering review. No human approvals.
Currentness
Original source edition; not a verified current-law consolidation. Signed at Dublin 2011-03-30; consent law 2011-11-01; gazette publication 2011-11-07. Treaty entry 2012-11-28, not application; entry notice dated 2013-02-11, published 2013-03-20. Article 32(2) general application from 2013-01-01 is qualified by tax-specific rules and transitional paragraphs 32(3)–(5). Historical original edition only. Later amending protocols signed 2014-12-03 and 2021-01-19 and a 2025 official consolidation are documented in the cached BMF article; none of their amended wording is imported here. The cache is not fresh currentness proof. This new edition does not replace the held 2025 intake or override its central audit. Later amendments, MLI effects and present-day applicability are not certified. Unreviewed machine transcription. Original 2011 publication only, not a verified current-law consolidation. No qualified human wording, legal, alignment, indexing, deployment or publication approval. Noindex preview only; noindex is not access control. Historical original edition only. Later amending protocols signed 2014-12-03 and 2021-01-19 and a 2025 official consolidation are documented in the cached BMF article; none of their amended wording is imported here. The cache is not fresh currentness proof. This new edition does not replace the held 2025 intake or override its central audit. Later amendments, MLI effects and present-day applicability are not certified.
Protocols and later instruments
Historical original edition only. Later amending protocols signed 2014-12-03 and 2021-01-19 and a 2025 official consolidation are documented in the cached BMF article; none of their amended wording is imported here. The cache is not fresh currentness proof. This new edition does not replace the held 2025 intake or override its central audit. Later amendments, MLI effects and present-day applicability are not certified. Source-triage warnings: Unreviewed machine transcription. Original 2011 publication only, not a verified current-law consolidation. No qualified human wording, legal, alignment, indexing, deployment or publication approval. Noindex preview only; noindex is not access control. Historical original edition only. Later amending protocols signed 2014-12-03 and 2021-01-19 and a 2025 official consolidation are documented in the cached BMF article; none of their amended wording is imported here. The cache is not fresh currentness proof. This new edition does not replace the held 2025 intake or override its central audit. Later amendments, MLI effects and present-day applicability are not certified. Known related/later instruments NOT included in this source (agent triage, not exhaustive): later-amending-protocol; signature date: 2014-12-03; limit: Cached BMF article; amendment body not incorporated; no current-law claim / later-amending-protocol; signature date: 2021-01-19; limit: Cached BMF article; amendment body not incorporated; no current-law claim / later-official-2025-consolidation; date: 2025-04-10; limit: Separate central record and held W intake preserved; no reclassification or body mixing
Text language and status
en · authentic-language-transcription · machine-transcription
Citation
BGBl. 2011 II S. 1042 (consent law); S. 1043–1067 (agreement, protocol and joint declaration)
BGBl. 2011 II S. 1042 (consent law); S. 1043–1067 (agreement, protocol and joint declaration) | de-ireland-2011-base | de-ireland-2011-base | BGBl. 2011 II S. 1042 (consent law); S. 1043–1067 (agreement, protocol and joint declaration) | signed 2011-03-30 | published 2011-11-07 | Signed: 2011-03-30 | Gazette publication: 2011-11-07 | Article 22 | en | Pending independent qualified human wording, completeness, currentness, alignment and rendering review. No human approvals. | /library/treaties/de-ireland-2011-base/en/articles/article-22/
Source, edition and limits
Source edition
de-ireland-2011-base | BGBl. 2011 II S. 1042 (consent law); S. 1043–1067 (agreement, protocol and joint declaration) | signed 2011-03-30 | published 2011-11-07 | Signed: 2011-03-30 | Gazette publication: 2011-11-07
Source form
Official original2011 PDF; reader from proved font-CMap-only derivative, not the original facsimile
Source scope
Original consent law, DE/EN convention, integral protocol and joint declaration; not amended/current law
Retrieved
2026-10-02
Text and language scope
Unreviewed machine transcription. Original 2011 publication only, not a verified current-law consolidation. No qualified human wording, legal, alignment, indexing, deployment or publication approval. Noindex preview only; noindex is not access control. Published treaty languages: German and English. Original closing on physical page 21 declares both texts equally authoritative. Both bodies come exclusively from the original 2011 PDF. No third language, translation or cross-language paragraph alignment is inferred. English interface; legal source containers carry their own language. Source-proved reversible blank-glyph CMap correction only; no OCR, translation, wording/spacing/hyphen repair. Native spans and coordinate gaps retained; all26 original/derivative renders identical. Law, preamble, execution, signatures, integral protocol and joint declaration: /review/de-ireland-2011-base/. Source links indicate pages, not independently approved paragraph alignment.
Review status
Pending independent qualified human wording, completeness, currentness, alignment and rendering review. No human approvals.
Currentness
Original source edition; not a verified current-law consolidation. Signed at Dublin 2011-03-30; consent law 2011-11-01; gazette publication 2011-11-07. Treaty entry 2012-11-28, not application; entry notice dated 2013-02-11, published 2013-03-20. Article 32(2) general application from 2013-01-01 is qualified by tax-specific rules and transitional paragraphs 32(3)–(5). Historical original edition only. Later amending protocols signed 2014-12-03 and 2021-01-19 and a 2025 official consolidation are documented in the cached BMF article; none of their amended wording is imported here. The cache is not fresh currentness proof. This new edition does not replace the held 2025 intake or override its central audit. Later amendments, MLI effects and present-day applicability are not certified. Unreviewed machine transcription. Original 2011 publication only, not a verified current-law consolidation. No qualified human wording, legal, alignment, indexing, deployment or publication approval. Noindex preview only; noindex is not access control. Historical original edition only. Later amending protocols signed 2014-12-03 and 2021-01-19 and a 2025 official consolidation are documented in the cached BMF article; none of their amended wording is imported here. The cache is not fresh currentness proof. This new edition does not replace the held 2025 intake or override its central audit. Later amendments, MLI effects and present-day applicability are not certified.
Protocols and later instruments
Historical original edition only. Later amending protocols signed 2014-12-03 and 2021-01-19 and a 2025 official consolidation are documented in the cached BMF article; none of their amended wording is imported here. The cache is not fresh currentness proof. This new edition does not replace the held 2025 intake or override its central audit. Later amendments, MLI effects and present-day applicability are not certified. Source-triage warnings: Unreviewed machine transcription. Original 2011 publication only, not a verified current-law consolidation. No qualified human wording, legal, alignment, indexing, deployment or publication approval. Noindex preview only; noindex is not access control. Historical original edition only. Later amending protocols signed 2014-12-03 and 2021-01-19 and a 2025 official consolidation are documented in the cached BMF article; none of their amended wording is imported here. The cache is not fresh currentness proof. This new edition does not replace the held 2025 intake or override its central audit. Later amendments, MLI effects and present-day applicability are not certified. Known related/later instruments NOT included in this source (agent triage, not exhaustive): later-amending-protocol; signature date: 2014-12-03; limit: Cached BMF article; amendment body not incorporated; no current-law claim / later-amending-protocol; signature date: 2021-01-19; limit: Cached BMF article; amendment body not incorporated; no current-law claim / later-official-2025-consolidation; date: 2025-04-10; limit: Separate central record and held W intake preserved; no reclassification or body mixing
Text language and status
en · authentic-language-transcription · machine-transcription
Citation
BGBl. 2011 II S. 1042 (consent law); S. 1043–1067 (agreement, protocol and joint declaration)
BGBl. 2011 II S. 1042 (consent law); S. 1043–1067 (agreement, protocol and joint declaration) · /library/originals/cb0eafbd040330600bb8c68e415d95c7360a5f9eebf1ddf2a25157b0705e3e7c.pdf
Disclaimers
Language switching retains matching article and paragraph identifiers. The mapping does not confirm reviewed legal or translational equivalence.
Source-page links are references, not human paragraph verification.