ARTICLE 26
EXCHANGE OF INFORMATION

1.         The competent authorities of the Contracting States shall exchange such information as is relevant for carrying out the provisions of this Convention or of the domestic laws of the Contracting States concerning taxes imposed by the Contracting States insofar as the taxation thereunder is not contrary to the Convention. The exchange of information shall apply to taxes of every kind and description and is not restricted by Article 1. Any information received by a Contracting State shall be treated as secret in the same manner as information obtained under the domestic laws of that State and shall be disclosed only to persons or authorities (including courts and administrative bodies) involved in the assessment or collection of, the enforcement or prosecution in respect of, or the determination of appeals in relation to, the taxes imposed on behalf of that State. Such persons or authorities shall use the information only for such purposes. They may disclose the information in public court proceedings or in judicial decisions.

2.         In no case shall the provisions of paragraph 1 be construed so as to impose on a Contracting State the obligation :

            (a)         to carry out administrative measures at variance with
                          the laws and administrative practice of that or of the
                          other Contracting State;

            (b)         to supply information which is not obtainable under
                          the laws or in the normal course of the administration
                          of that or of the other Contracting State;

             (c)         to supply information which would disclose any trade,
                          business, ndustrial, commercial or professional secret
                          or trade process, or information, the disclosure of which
                          would be contrary to public policy (ordre public).

ARTICLE 27
MEMBERS OF DIPLOMATIC MISSIONS AND CONSULAR POSTS

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

CHAPTER VI
FINAL PROVISIONS

ARTICLE 28
ENTRY INTO FORCE

1.         Each of the Contracting States shall notify to the other the completion of the procedures required by its law for the bringing into force of this Convention.

2.         This Convention shall enter into force thirty day after the exchange of the instruments of ratification and shall for the first time have effect:

            (a)         In Thailand:

                          (i)         in respect of taxes withheld at the source, on
                                       amounts paid or remitted on or after the first day
                                       of January in the calendar year next following
                                       that in which the Convention enters into force;

                          (ii)        in respect of other taxes on income, for taxable
                                       years or accounting periods beginning on or
                                       after the first day of January in the calendar year
                                       next following that in which the Convention enters
                                       into force.

            (b)        In Norway:

             in respect of taxes on income relating to the calendar year (including accounting periods beginning in any such year) next following that in which the Convention enters into force and subsequent years.

3.         The Convention between the Royal Government of Norway and the Royal Government of Thailand for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital, signed in Bangkok on 9 January 1964, shall cease to have effect from the date on which this Convention becomes effective in accordance with paragraph 2 of this Article.

ARTICLE 29
TERMINATION

            This Convention shall remain in force indefinitely, but either of the Contracting States may, on or before 30th June in any calendar year beginning after the expiration of a period of five years from the date of its entry into force, give to the other Contracting State, through diplomatic channels, written notice of termination.

             In such event the Convention shall cease to have effect:

            (a)        in Thailand :

                         (i)         in respect of taxes withheld at the source, on
                                      amounts paid or remitted on or after the first day
                                      of January in the calendar year next following
                                      that in which the notice is given;

                         (ii)        in respect of other taxes on income, for taxable
                                      years or accounting periods beginning on or
                                      after the first day of January in the calendar year
                                      next following that in which the notice is given.

            (b)        in Norway, in respect of taxes on income relating to the
                          calendar year (including accounting periods beginning
                          in such year) next following that in which the notice is given.

            IN WITNESS WHEREOF, the undersigned duly authorized thereto, have signed this Convention.

             Done in duplicate at Bangkok on this 31st day of July, Two thousand and three Year of the Christian Era, each in the English language.

PROTOCOL

             At the signing of the Convention between the Kingdom of Thailand and the Kingdom of Norway for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income, the undersigned have agreed upon the following provisions which shall form an integral part of the Convention.

1.         With reference to Article 7 it is understood that nothing in this Article shall affect the application of any tax law of a Contracting State relating to the tax assessment of a person in cases where the information available to the tax authorities of that State is inadequate to determine the taxable profits of that person, provided that the result shall be in accordance with the principles contained in this Article.

2.         With reference to paragraph 2 of Article 8, it is understood that the lesser of the tax rate applied by a Contracting State on income derived by an enterprise of a third state from the operation of ships in international traffic, then such a lower tax rate shall apply in relation to the other Contracting State.

3.         The term "profits" in Article 7 and 9 shall refer to income or profits.

4.         With reference to paragraph 2 of Article 11, if after the signature of this Convention a Contracting State concludes a Convention for the avoidance of double taxation with a third State, in which the tax on interests is agreed upon at a lower rate than in this Convention, then such a lower tax rate shall apply in relation to the other Contracting State.

              IN WITNESS WHEREOF, the undersigned duly authorized thereto, have signed this Protocol.

              Done in duplicate at Bangkok on this 31st day of July, Two thousand and three Year of the Christian Era, each in the English language.

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