PAYMENTS TO PROFESSORS, TEACHERS AND RESEARCHERS
���� �������������������An� individual who� is or was immediately� before visiting a� Contracting State a resident of the other Contracting� State, and who, at the invitation of� any university,� college, school or other similar educational�� institution which �is �recognized by respective authorities in the first-mentioned� Contracting State, visits� that first-mentioned� Contracting State for a� period not exceeding two years solely for the purpose of teaching or research� or both at such educational institution shall be� exempt from tax in� that� other Contracting State on� any� remuneration� for such teaching or research.
OTHER INCOME
� ���������������������� Items of income of a resident of a Contracting State not dealt with in the foregoing Articles of this Convention may be taxed in the State where the income arises.
METHOD OF ELIMINATION OF DOUBLE TAXATION
� ����������������������1. ������The laws in force in either of the Contracting States shall continue� to� govern� the taxation� of� income� in the respective Contracting� States� except� where� express� provisions�� to� the contrary are made in this Convention.� Where income is subject to� tax in both Contracting States, relief from double taxation shall� be� given in� accordance� with� the following paragraphs� of this Article.
��� ����������������������2. �������In the case of Thailand, Russian tax payable in respect of income derived from Russia shall be allowed as a credit against Thai tax payable in respect of that income. The credit shall not, however, exceed that part of the Thai tax, as computed before the credit is given, which is appropriate to such item of income. However,� where such income is a dividend paid by a company which� is a resident� of� Russia� to� a company which is� a� resident of� Thailand and which owns not�� less than 25 per cent of the voting shares of the company� paying the dividend Thailand� shall exempt such income from tax but may in calculating tax� on the remaining income of� that� person,� apply the rate of tax� which would have� been applicable if the exempted income had not been so exempted.
��� �����������������������3. ����In the case of Russia, Thai tax payable in respect of income derived from Thailand shall be allowed as a credit against Russian tax payable in respect of that income.� The credit shall not,�� however, exceed that part of the Russian tax, as computed before the credit is given, which is appropriate to such item of income.� For� the purpose of� this paragraph,� the term "Thai tax� payable"� shall be deemed to include the amount of Thai tax which would have� been paid if� the Thai� tax had not been� exempted or reduced in accordance with the special incentive laws designed to promote�� economic development in Thailand, effective on the date of signature of� this� Convention,� or which� may� be introduced� hereafter in� modification� of,� or in addition to,� the existing� laws.
NON-DISCRIMINATION
��� ��������������������1.���� Nationals� of� a� Contracting� State,� legal persons and partnerships� registered under� the laws of a� Contracting State,� shall not�� be� subjected in� the other Contracting State� to any taxation or any requirement connected therewith which is other or more burdensome than� the taxation and� connected requirements to which nationals of that other State,� as the case may be,� in the same circumstances are or may be subjected.� The provision shall, notwithstanding�� the�� provisions of Article 1, also apply to persons who are not residents of� one or both of� the Contracting� States.
�� ���������������������2. �����The� taxation� on� a� permanent� establishment� which an enterprise� of a Contracting� State has in� the other Contracting State shall not be� less� favourably� levied in that� other State than the taxation levied on the enterprises of� that� other State carrying on the same activities.
��� ��������������������3.��� Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly,� by one or more residents of the other Contracting State, shall �not be subjected in the first-mentioned �State to �any �taxation �or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which other similar enterprises of the first-mentioned State are or may� be subjected.
��� ��������������������4. ���The provisions of this Article shall not� be construed as� obliging a Contracting State to grant to� residents of� the other Contracting State any personal allowances, reliefs and reductions for taxation� purposes� on� account� of� civil� status� or family� responsibilities which it grants to its own residents.
�� ���������������������5. ����The provisions of this Article shall only apply to the taxes which are the subject of this Convention.
MUTUAL AGREEMENT PROCEDURE
��� ���������������������1.��� �Where a resident of a Contracting State considers that the� actions of one or both of the Contracting States� result� or will result� for� him� in� taxation� not�� in� accordance�� with� this Convention,� he may, irrespective of the remedies provided by the domestic law of those States,� present his case to the competent authority of the Contracting State of which he is a resident.� The case must� be� presented� within three years from the first notification� of� the�� action� resulting� in�� taxation� not� in accordance with the provisions of this Convention.
��� ����������������������2.���� The competent authority shall endeavour, if the objection appears to it� to be justified and if� it� is not� itself able to arrive at a satisfactory solution,� to resolve the case by mutual agreement with the competent authority of� the� other Contracting State with a view to� the avoidance of� taxation which� is not in accordance with the Convention.�
��� ����������������������3.���� The competent authorities of the Contracting States shall endeavour to resolve by mutual agreement any difficulties or doubts arising as to the interpretation or application of the Convention.
��� ����������������������4. The competent authorities of the Contracting State may ���communicate with each other directly for the purpose of reaching an agreement in�the sense of the preceding paragraphs.