Aberdeen – Stavanger Gateway 3 June 2014 International Tax Issues Kevin R Mann

Overall Tax Objectives – International Projects Minimise risk of overseas tax compliance failure Understand project Overall Objectives “Proactive and Commercial” Overall Objectives “Proactive and Commercial” Review/amend onerous contract terms Understand & minimise overseas tax exposures Factor additional tax/compliance costs in bid price “AAB are providing us with advice regarding our overseas employee assignments to Norway. In addition to providing us with guidance from a company perspective, AAB prepared summaries targeted at the employee’s perspective and these were particularly useful in effectively managing our communication of these sometimes delicate issues with our employees affected. We are confident that AAB will keep us on track in relation to our compliance obligations in Norway and are very pleased with the comprehensive and efficient service provided by the AAB team.” Alan Cormack Nautronix

Corporate Tax Considerations UK – 21% (20% from 1 April 2015) Norway – 27% Rates of Corporation Tax on profits of PE? Influence of UK / Norway Double Tax Treaty (DTT) Onshore (Art 5) – Various definitions of PE Offshore (OA’s) (Art 21) – Deemed PE if OA’s > 30 days in any 12-mth period Carrying on Business in overseas country through permanent establishment (PE)? Subsidiary v Branch / PE in overseas country? Tax rates as above Repatriation of post-tax profits? Other Indirect Taxes? VAT? PAYE / Wage tax? Customs duties? Overseas professional fees? Double Tax Relief in Home Country? UK – Restricted to 21% (20% from 1 April 2015) – 6% (7%) incremental tax cost Norway – Likely full credit obtained

Employment Tax Considerations Double Wage Tax deductions (UK and Norway)? Need to be managed  UK – Net of Tax Credit arrangement  Norway – Double Tax Credit Relief PAYE / Wage Tax Obligations of Employer? Influence of UK / Norway DTT Onshore (Art 14) – Conditions for exemption Offshore (OA’s) (Art 21) – All remuneration liable to tax Income Tax Payable in Overseas Country? National Insurance Liabilities? Continuing liability in home country (A1 Certificate)? Both employee and employer contributions Rates of Income Tax Payable? UK – 20%, 40%, 45% Norway – 27%, 36%, 39% "As a company we routinely are called to tender for projects in what are ‘frontier’ regions for us often with complex tax regimes and testing legislation relating to international suppliers. Thorough, up to date and concise advice underpin our commercial proposals, and in these respects AAB have never failed to deliver, even at very short notice” Gary Thirkettle Calecore Limited

International Tax Team – who’s who Contact Details Kevin R Mann - Partner Telephone: