http://www.legislation.gov.uk/id/ukdsi/2001/3925

SCHEDULE

PART ICONVENTION BETWEEN THE GOVERNMENT OF THE UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND AND THE GOVERNMENT OF THE REPUBLIC OF LITHUANIA FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME AND ON CAPITAL GAINS

Article 23Miscellaneous rules applicable to certain Offshore Activities

(5)

Subject to paragraph (6) of this Article profits derived by an enterprise of a Contracting State from the operation, in connection with offshore activities carried on in the other Contracting State, of ships or aircraft which are in their existing state designed primarily for the purpose of transporting supplies or personnel, or of tug-boats or anchor handling vessels, shall be taxable only in the State of which the enterprise is a resident.