ARTICLE 21
Private Pensions and Annuities

            Income in the nature of pensions or other remunerations for past employment from sources within one of the Contracting States and paid to a resident of the other Contracting State may be taxed in the fist mentioned State.

ARTICLE 22
Consulation

1.         The Competent authorities of the Contracting States may communicate with each other directly for the purpose of giving effect to the provisions of the present Convention.  Should any difficulty or doubt arise as to the interpretation or application of the present Convention, the competent authorities shall endeavour to settle the question as quickly as possible by mutual agreement.

2.         In particular, the cometent authorities of the Contracting States may consult together to endeavour to agree

            (a)        to the same attribution of industrial or commercial profits to a

                         resident or corporation of one of the Contracting States and

                         to its paragraph establishment situated in the other

                         Contracting State;

            (b)        to the same allocation of income between a resident or

                         corporation of one of the Contracting States and any related

                         person, provided for in Article 10.

            In the event that the competent authorities reach such an agreement, taxed shall be imposed on such income and refund or credit of taxes shall be allowed by the Contracting States in accordance with such agreement.

ARTICLE 23
Exchange of Information

1.         The competent authorities of one of the contracting States shall exchange such information with the competent authorities of the other Contracting State as is pertinent to carrying out the provisions of the present Convention or preventing fraud or fiscal evasion is relation to the taxes which are the subject of the present Convention.

2.         The competent authorities of the Contracting State to which a request for information is made shall not exchange information if that information is not available under the taxation laws and administrative procedures of that State, or that information is such as which would disclose any trade, business, industrial, or professional secret.

3.         Any information exchanged shall be treated as secret but may be disclosed to persons (including a court or administrative body) concerned with assessment, collection, enforcement or prosecution with respect to the taxes which are the subject of the present Convention.

4.         The competent authorities of the Contracting States shall notify each other of any amendments of the tax laws referred to in Article 1 (1) and of the adoption of any taxes referred to in Article 1 (2) by transmitting the texts of any amendments or new statutes at least once a year.

ARTICLE 24
Assistance in Collection

1.         Each of the Contracting States shall endeavour to collect such taxes imposed in the other Contracting State as will ensure that any exemption or reduced rate of tax granted under the present Convention in the other State shall not be enjoyed by persons not entitled to such benefits.  The Contracting State making such collections shall be responsible to the other Contracting State for the sums thus collected.

2.         In no case shall the provisions of this Article be construed so as to impose upon either of the Contracting States the obligation to carry out administrative measures which are at variance with the regulations and practices of the Contracting State endeavouring to collect the tax or which would be contrary to that State's public policy.

ARTICLE 25
Taxpayer Claims

            A taxpayer shall be entitled to present his case to the competent authorities of the Contracting State of which he is a national or resident, or, if the taxpayer is corporation of one of the Contracting States, to that State, if he considers that the action of the other Contracting State has resulted, or will result for him in taxation contrary to the provisions of this Convention.  Should the taxpayer's claim be considered to have merit by the competent authorities of the Contracting State to which the claim is made, the competent autorities shall endeavour to come to an agreement with the competent authorities of the other Contracting State with a view to the avoidance of taxation not in accordance with the provisions of the Convention.

ARTICLE 26
Effective Dates and Ratification

1.         The present Convention shall be ratified and the instrument of ratification shall be exchanged at Seoul as soon as possible.

2.         (a)        The present Convention shall enter into force upon the

                          thirtieth day after the date of the exchange of instruments of

                          ratification.

            (b)        The present Convention shall be applicable for the taxable

                          years (or taxable periods) or acounting periods beginning

                          on or after the first day of January of the calendar year in

                          which the present Convention enters into force.

3.         The present Convention shall continue in effect indefinitely but either Contracting States may, on or before the thirtieth day of June in any calendar year beginning after the expiration of a period of five years from the dated of its entry into force, give to the other Contracting State, through the diplomatic channel, written notice of termination and, in such event, the present Convention shall cease to be effective for taxable years beginning on or after the first day of January in the calendar year next following that in which the notice is given.  Done at Bangkok on August 26, 1974 , in six originals two each in Korean, in Thai and in English, each text being equally authoritative but in case of divergence the English text shall prevail.

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