(a) where a company in one territory operating at sea in another territory is linked to another undertaking that engages in essentially similar activities at sea, the first entity created is considered to be all of these activities, with the exception of activities carried out simultaneously with its own activities; (a) Manx tax, which, according to the laws of the Isle of Man and in accordance with that agreement, either directly or by deduction, on profits, income or taxed profits from sources located in the Isle of Man (with the exception of a tax on dividends payable for the profits under which the dividend is paid) is accepted as a credit against any UK tax. , taxable income or profits on which manx tax is levied; (i) for taxes withheld at source for amounts paid or credited on the first day of the second month following the effective date of this agreement; 4. Where a request for the turnover of an area is a right for which that territory may, under its legislation, take conservation measures to ensure its recovery, that right to turnover is accepted, at the request of the competent authority of that territory, in order to take conservation measures on the part of the competent authority of the other territory. This other territory, in accordance with the provisions of its legislation, takes conservation measures with respect to this revenue request, as if the revenue requirement were a request for revenue from that other territory, even if, at the time of the application of these measures, the debt is not enforceable in the aforementioned area or is owed by a person entitled to prevent their recovery. (a) he is considered to be a resident only of the territory in which he has a permanent homeland; if he has a permanent homeland in both territories, he is considered only a resident of the territory with which his personal and economic ties are closer (vital interests); 6. Procedures relating to the existence, validity or amount of a right to revenue from one territory are not brought before the courts or administrative bodies of the other territory. The Government of the United Kingdom of Great Britain and Northern Ireland and the Isle of Man Government have agreed on the following provisions, which should be an integral part of the agreement between the Government of the United Kingdom of Great Britain and Northern Ireland and the Isle of Man Government on the elimination of double taxation on income and capital gains and the prevention of fraud and evasion (“”).