(9) Gains derived by a resident of a Contracting State from the alienation of:
(a)exploration or exploitation rights; or
(b)property situated in the other Contracting State and used in connection with the exploration or exploitation of the sea bed and sub-soil and their natural resources situated in that other State; or
(c)shares deriving their value or the greater part of their value directly or indirectly from such rights or such property or from such rights and such property taken together
may be taxed in that other State. In this paragraph the term “exploration or exploitation rights” means rights to assets to be produced by the exploration or exploitation of the sea bed and sub-soil and their natural resources in the other Contracting State, including rights to interests in or to the benefit of such assets.