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 laws 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. They may also consult together for the elimination of double taxation in cases not provided for in the Convention.
4. The competent authorities of the Contracting States may communicate with each other directly for the purposes of reaching an agreement in the sense of the preceding paragraphs.
MEMBERS OF DIPLOMATIC MISSIONS
Nothing in this Convention shall affect the fiscal privileges of members of diplomatic missions or consular posts under the general rules of international law or under the provisions of special agreements.
ENTRY INTO FORCE
This Convention shall be ratified and the instruments of instruments of ratification and its provisions shall have effect:
(a) in respect of taxes withheld at the source, on amounts paid or remitted
This Convention shall remain in force indefinitely, but either of the Contracting States may, on or before 30th June in any calendar year beginning after the expiration of a period of five years from the date of its entry into force, give to the other Contracting State, through diplomatic channels, written notice of termination.
In such event the Convention shall cease to have effect:
(a) in respect of taxes withheld at the source, on amounts
(b) in respect of other taxes on income, for taxable years or
in Thailand, the 1st day of January next following that in
IN WITNESS WHEREOF, the undersigned duly authorized thereto, have signed this Convention.
Done in duplicate at Bangkok on this 3rd day of November, Two thousand and one each in the Thai, Arabic and English languages all texts being equally authoritative, except in the case of doubt when the English text shall prevail.