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.