1          A professor or teacher who visits one of the Contracting State  for  a period not exceeding two years for the purpose of teaching  or  engaging  in  research at a university, college or other recognized educational institution in that Contracting State and who was immediately before that visit a resident of the other Contracting  State,  shall  be  exempted  from tax by the first-mentioned Contracting State on any remuneration for such teaching or  research for a period not exceeding two years from the date he first visits that State for such purpose.


2          This Article shall only apply to income from research if such  research is undertaken by the professor or teacher in the public  interest and not primarily for the benefit of some other private person or persons.




1          Nothing  in  this  Convention  shall affect the fiscal privileges of diplomatic or consular officials under the general rules  of  international law or under the provisions of special agreements.


2          Notwithstanding   paragraph  (1)  of  Article  4,  an individual  who  is  a  member  of  the  diplomatic, consular or permanent mission of a Contracting State or any third State which is situated in the other Contracting State and who is within the scope  of  the  Vienna  Convention (1) shall not be treated as a resident of that other State.




1          In  the  case of the United Kingdom and subject to the provisions  of  the  law  of  the  United  Kingdom regarding the allowance  as a credit against United Kingdom tax of tax payable in a territory outside the United Kingdom (Which shall not affect the general principle hereof):

            (a)        Thai tax payable under the laws of Thailand and in

                         accordance with this Convention, whether directly or by

                         deduction,  on  profits,  income or chargeable gains  from

                         sources within Thailand (excluding in the  case of a dividend,

                         tax payable in respect of the  profits  out  of  which  the

                         dividend is paid)  shall  be  allowed  as a credit against any

                         United Kingdom  tax  computed  by  reference  to the same

                         profits, income or chargeable gains by reference to which the

                         Thai tax is computed.

            (b)        Where  a  dividend is paid by a company which is a resident

                         of  Thailand  to  a  company  which is a resident  of the

                         United Kingdom and which controls directly or indirectly at

                         least 25 percent of the voting  power  in the company paying

                         the dividend, the  credit  shall take account (in addition to any

                         Thai tax for which credit may be allowed under the provisions

                          of sub-paragraph (a) of this paragraph) the  tax  payable by

                         the company in respect of the profits out of which such

                         dividend is paid.


2          For the purposes of paragraph (1) of this Article, the term  “Thai tax payable” shall be deemed to include any amount which would have been payable as Thai tax for any year but for an exemption  or reduction of tax granted with a view to promoting industrial,   commercial,   scientific,   educational  or  other development in Thailand, for that year or any part thereof under:

            (a)        Sections 31 and 35 (3) (but only to the extent the  exemption

                         or  reduction  allowed  by  those provisions  would not have

                         been available if those provisions  had  not been enacted),

                         33, 34, 35 (2) and 35 (4) of the Investment Promotion Act B.E.

                         2520 so  far as they were in force on, and have not been

                         modified since, the date of signature of this Convention,  or 

                         have  been modified only in minor  respects  so  as  not  to 

                         affect  their  general character; or

            (b)        any other provision which may subsequently be made

                         granting an exemption or reduction of tax which is agreed 

                         by   the  competent  authorities  of  the Contracting State to be

                         of a substantially similar character,  if it has not been

                         modified thereafter or  has been modified only in minor

                         respects so as not to affect its general character. Provided

                         that relief  from United Kingdom tax shall not be given by 

                         virtue  of this paragraph in respect of income from  any 

                         source if the income arises in a period starting  more  than 

                         ten years after the exemption from  or reduction of Thai tax

                         was first granted in respect of that source.


3          In the case of Thailand, United Kingdom tax payable in accordance with this Convention in respect of income from sources within  the United Kingdom 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.


4          For  the  purposes  of  paragraphs (1) and (3) of this Article profits, income and capital gains owned by a resident of a Contracting State which may be taxed in the other Contracting State  in  accordance with this Convention shall deemed to arise from sources in that other Contracting State.


5          Where  profits on which an enterprise of a Contracting State has been charged to tax in that state are also included in the profits of an enterprise of the other State and the profits so  included  are  profits  which  would  have  accrued  to that enterprise of the other State if the conditions made between the enterprises  had  been  those which would have been made between independent  enterprises  dealing wholly independently with each other,  the  amount  included in the profits of both enterprises shall be treated for the purposes of this Article as income from a source  in  the  other  State  of the enterprise of the first-mentioned State and relief shall be given accordingly under the provisions of paragraph (1) or paragraph (3) of this Article.




1          The  nationals  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  in  the same circumstances are or may be subjected.


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  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, by one or more  residents  of  the  other  Contracting State, shall not be subjected  in  the  first-mentioned  Contracting  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 that first-mentioned State are or may be subjected.


4          Nothing contained in this Article shall be construed as obliging  either  Contracting State to grant to individuals not resident  in  that state any of the personal allowances, reliefs and reductions for tax purposes which are granted to individuals so resident.


5          In this Article the term "taxation" means taxes of every kind and description.




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, notwithstanding the remedies provided by the national laws  of  those  states,  present  this  case  to  the competent authority of the Contracting  State of which he is a resident.


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 an appropriate 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 not


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 States may communicate with each other directly for the purpose of reaching  an agreement in the sense of the preceding paragraphs.




Last updated: 08.12.2011