Artikel 2

1. The exploitation of the Sillimanite Field shall be undertaken in accordance with the terms of this Agreement.
2. Each Party shall require or ensure that their relevant Competent Authority requires its Licensees to conclude a Licensees’ Agreement with the Licensees of the other Party. The Licensees’ Agreement, as well as any proposal to amend, modify or otherwise change, or to waive or depart from, the provisions of the Licensees’ Agreement, including the apportionment of benefits and costs of the Sillimanite Field, shall require the approval of the Parties or their Competent Authorities before any such proposal may be implemented by the Licensees. In the event that a Redetermination is undertaken in accordance with the Licensees’ Agreement, any statement or instrument issued by the Unit Operator documenting any change shall not become effective unless and until both Parties or their Competent Authorities have approved that statement or instrument.
3. A unit operator shall be appointed by agreement between the Licensees as their joint agent for the purpose of exploiting the Sillimanite Field in accordance with this Agreement (the “Unit Operator”). The appointment of and any change to the Unit Operator shall be subject to prior approval by the Parties or the Parties’ relevant Competent Authority.
4. Production shall not commence until the Development Plan for the Sillimanite Field has been approved by the Parties or the Parties’ relevant Competent Authority.
5. Drilling, maintenance and suspension of boreholes from an installation on the Sillimanite Field under the United Kingdom Continental Shelf shall be considered to fall under Dutch legislation. Both Parties shall be informed or ensure that the relevant Competent Authority is informed by the Unit Operator of the exact position of each borehole.
6. Profits and capital gains arising from the Sillimanite Field shall be taxed in accordance with the laws of the United Kingdom and the Netherlands respectively, including the Convention between the Government of the Kingdom of the Netherlands and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital Gains, done at London on 26 September 2008, the Protocol done at London on 12 June 2013 and any Protocol or Protocols to that Convention or any Convention replacing that Convention as may be signed in the future.
7. Neither Party or its relevant Competent Authority shall permit production from the Sillimanite Field until the respective tax authorities of the two Parties have reached agreement regarding the taxation of the profits and gains arising from such production.