ARTICLE 21
Professors, Teachers and Researchers

1.         An individual who is a resident of a Contracting State immediately before making a visit to the other Contracting State, and who, at the invitation of any university, college, school or other similar educational institution, which is recognised by the competent authority in that other Contracting State, visits that other Contracting State for a period not exceeding two years solely for the purpose of teaching or research or both at such educational institution shall be exempt from tax in that other Contracting State on any remuneration for such teaching or research.

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

ARTICLE 22
Students

1.         Payments which a student, or business apprentice or trainee, who is or was immediately before visiting a Contracting State a resident of the other Contracting State and who is present in the first-mentioned Contracting State solely for the purpose of his education or training, shall not be taxed in the first-mentioned State, for a period of six years, provided that such payments are made to him from outside that State.

2.         Such student, or apprentice or business trainee will also be exempted from any income tax for a period of two years in respect of any remuneration received for services exercised as an employee in that first State, provided that such services are in connection with his studies, or practical training or are necessary for the purpose of his maintenance.

ARTICLE 23
Income Not Expressly Mentioned

             Items of income of a resident of a Contracting State which are not expressly mentioned in the foregoing Articles of this Convention may be taxed in the Contracting State where the income arises.

ARTICLE 24
Elimination of Double Taxation

1.         Where income is subject to tax in both Contracting States, relief from double taxation shall be given in accordance with the following paragraphs of this Article.

2.         In the case of Thailand, Romanian tax payable in respect of income from sources within Romania 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.

3.         In the case of Romania, Thai tax payable in respect of income derived from Thailand shall be allowed as a credit against Romanian tax payable in respect of that income.

4.         For the purposes of paragraph 3 of this Article, the term "Thai tax payable" shall be deemed to include the amount of Thai tax which would have been paid if the Thai tax had not been exempted or reduced in accordance with the special incentive laws designed to promote economic development in Thailand, effective on the date of signature of this Convention, or which may be introduced hereafter in modification of, or in addition to the existing laws.

ARTICLE 25
Non-Discrimination

1.         The nationals of a Contracting State, whether or not residents of the mentioned 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 of 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 or indirectly, 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.         In this Article, the term "taxation" means taxes which are the subject of this Convention.

Page 123456

Article : [ 1 ][ 2 ][ 3 ][ 4 ][ 5 ] [ 6 ][ 7 ][ 8 ][ 9 ][ 10 ][ 11 ][ 12 ][ 13 ][ 14 ][ 15 ][ 16 ][ 17 ][ 18 ][ 19 ][ 20 ][ 21 ][ 22 ][ 23 ][ 24 ][ 25 ][ 26 ][ 27 ][ 28 ][ 29 ][ 30 ]