It is understood that exploration and exploitation rights of natural resources, including rights to interests in, or to the benefits of, assets to be produced by such exploration or exploitation, shall be regarded as immovable property situated in the Contracting State the sea bed and sub-soil of which they are related to, and that these rights shall be deemed to pertain to the property of a permanent establishment in that State and the profits attributable to the permanent establishment shall be taxable in accordance with the national tax laws and regulations of that State.