ARTICLE 21
OTHER INCOME 1. Items of income of a resident of a Contracting State, wherever arising, not dealt with in the foregoing Article of this Convention shall be taxable only in that State. 2. The provisions of paragraph 1 shall not apply to income, other than income from immovable property as defined in paragraph 2 of Article 6, if the recipient of such income, being a resident of a Contracting State, carries on business in the other Contracting State through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the income is paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 3. Notwithstanding the provisions of paragraphs 1 and 2, items of income of a resident of a Contracting State not dealt with in the foregoing Articles of this Convention and arising in the other Contracting State may be taxed in that other State. ARTICLE 22
UNDIVIDED ESTATE 1. Where under the provisions of this Convention a resident of a Contracting State is exempt or entitled to relief from tax in the other Contracting State, similar exemption or relief shall be applied to the undivided estate of a deceased person in so far as one or more of the beneficiaries is a resident of the first-mentioned Contracting State. Such exemption or relief shall however be applied only to the part of income to which such beneficiary is entitled. 2. Where the undivided estate of a deceased person has been subject to tax on income in a Contracting State in accordance with the provisions of paragraph 1 of this Article, a beneficiary who is a resident of the other Contracting State shall be granted relief from tax in that other State in accordance with the provisions of Article 23. ARTICLE 23
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 State except where express provisions to the contrary are made in this Convention. 2. In the case of Thailand, where a resident of Thailand derives income which, under the laws of Sweden and in accordance with the provisions of this Convention, may be taxed in Sweden, Thailand shall allow as a deduction from Thai tax on such income, an amount equal to the tax paid in Sweden. Such deduction shall not, however, exceed that part of the Thai tax, as computed before the deduction is given, which is appropriate to the income derived from Sweden. 3. In the case of Sweden, double taxation shall be avoided as follows : a) Where a resident of Sweden derives income which under the laws of Thailand and in accordance with the provisions of this Convention may be taxed in Thailand, Sweden shall allow-subject to the provisions of the law of Sweden concerning credit for foreign tax (as it may be amended from time to time without changing the general principle hereof) - as a deduction from the tax on such income, an amount equal to the Thai tax paid in respect of such income. For the application of this subparagraph, the following rules shall apply : (i) The Thai tax paid on dividends which are not exempted from Swedish tax under the provisions of paragraph 4 of Article 10 and received by a company, other than a partnership, which is a resident of Sweden shall, in any case, be deemed to have been paid at rate of 25 per cent of the gross amount of the dividends; (ii) The Thai tax paid on royalties, in accordance with the provisions of paragraph 2 of Article 12, shall, in any case, be deemed to have been paid at the rate of 20 per cent of the gross amount of the royalties; (iii) The term "Thai tax paid", as used in this subparagraph, shall be deemed to include the amount of Thai tax which would have been paid if exemption from or reduction of Thai tax had not been granted in accordance with the special incentive laws, effective on the date of signature of this Convention, or which, subject to the agreement by the competent authorities of the Contracting States, may be introduced hereafter in modification of, or in addition to the existing laws. b) Notwithstanding the provisions of subparagraph (a) of this paragraph where a resident of Sweden derives income or gains which, in accordance with the provisions of Articles 7 or 14 or paragraph 2 of Article 13 may be taxed in Thailand, Sweden shall exempt such income or gains from tax provided that the principal part of the income or gains arises from independent personal services or business activities, other than the management of securities and other similar property. c) Where a resident of Sweden derives income which, in accordance with provisions of Article 18, shall be taxable only in Thailand, or income or gains which, in accordance with the provisions of subparagraph (b) of this paragraph, shall be exempted from Swedish tax, Sweden may, when determining the graduated rate of Swedish tax, take into account the income which shall be taxable only in Thailand or the income or gains which shall be exempted from Swedish tax, respectively. ARTICLE 24
NON-DISCRIMINATION 1. 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 enterprise of that other State carrying on the same activities. This provision 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. 3. Except where the provisions of paragraph 1 of Article 9, paragraph 7 of Article 11, or paragraph 6 of Article 12, apply, interest, royalties and other disbursements paid by an enterprise of a Contracting State to a resident of the other Contracting State shall, for the purpose of determining the taxable profits of such enterprise, be deductible under the same conditions as if they been paid to a resident of the first-mentioned State. 4. 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. ARTICLE 25
MUTUAL AGREEMENT PROCEDURE 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of 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 or, if his case comes under paragraph 1 of Article 24, to that of the Contracting State of which he is a national. 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 the 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 purpose of reaching an agreement in the sense of the preceding paragraphs. The competent authorities shall, through consultations, develop appropriate bilateral procedures, conditions, methods and techniques for the implementation of the mutual agreement procedure provided for in this Article. | 
