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 recognized 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 only apply to income from research if such research is undertaken by the individual for the public interest and not primarily for the benefit of some other private person or persons. ARTICLE 22
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 shall be taxable only in that State except that, if such income is derived from sources within the other Contracting State, it may also be taxed in that other State. ARTICLE 23
CAPITAL 1. Capital represented by immovable property referred to in Article 6, owned by a resident of a Contracting State and situated in the other Contracting State, may be taxed in that other State. 2. Capital represented by movable property forming part of the business property of a permanent establishment which an enterprise of a Contracting State has in the other Contracting State or by movable property pertaining to a fixed base available to a resident of a Contracting State in the other Contracting State for the purpose of performing independent personal services, may be taxed in that other State. 3. All other elements of capital of a resident of a Contracting State shall be taxable only in that State. ARTICLE 24
ELIMINATION OF DOUBLE TAXATION 1. The laws in force in either of the Contracting States shall continue to govern the taxation of income and capital in the respective Contracting States except where express provisions to the contrary is made in this Convention. When income or capital 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 double taxation shall be avoided as follows: Subject to the laws of Thailand regarding the allowance as a credit against Thai tax of tax payable in any country other than Thailand, where a resident of Thailand derives income from Luxembourg which may be taxed in Luxembourg in accordance with the provisions of this Convention, the amount of Luxembourg tax payable in respect of that income shall be allowed as a credit against the Thai tax imposed on that resident. The amount of credit shall not, however, exceed that part of the Thai tax which is appropriate to that income. 3. In the case of Luxembourg double taxation shall be avoided as follows: (a) Where a resident of Luxembourg derives income or owns capital which, in accordance with the provisions of this Convention, may be taxed in Thailand, Luxembourg shall, subject to the provisions of sub-paragraphs b) and c), exempt such income or capital from tax, but may, in order to calculate the amount of tax on the remaining income or capital of the resident, apply the same rates of tax as if the income or capital had not been exempted. (b) Where a resident of Luxembourg derives income which, in accordance with the provisions of paragraph 2 of Article 8, Articles 10, 11, 12, paragraph 4 of Article 13 and Article 22 may be taxed in Thailand, Luxembourg shall allow as a deduction from the tax on the income of that resident an amount equal to the tax paid in Thailand. Such deduction shall not, however, exceed that part of the tax, as computed before the deduction is given, which is attributable to such items of income derived from Thailand. (c) Where a company which is a resident of Luxembourg derives dividends from Thai sources, Luxembourg shall exempt such dividends from tax, provided that the company which is a resident of Luxembourg holds directly at least 25 per cent of the capital of the company paying the dividends since the beginning of the accounting year. The above-mentioned shares in the Thai company are, under the same conditions, exempt from the Luxembourg capital tax. (d) For the purposes of sub-paragraph b), the term "the tax paid in Thailand" shall be deemed to include the amount of Thai tax which would have been paid under the laws of Thailand, if the Thai tax had not been exempted or reduced in accordance with any special incentive law 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 law, provided that the amount of the tax referred to in this sub-paragraph shall not, however, exceed: (i) 15 per cent of the gross amount of dividends; (ii) 10 per cent of the gross amount of interest referred to in sub-paragraph (a) of paragraph 2 of Article 11; (iii) 15 per cent of the gross amount of interest referred to in sub-paragraph (b) of paragraph 2 of Article 11; (iv) 15 per cent of the gross amount of royalties. The provisions of this sub-paragraph shall only apply for a period of 12 years beginning on the first day of January of the taxable year next following that in which this Convention enters into force. This period may be extended by mutual agreement between the competent authorities. ARTICLE 25
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 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 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. 4. The provisions of this Article 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. 5. The provisions of this Article shall only apply to the taxes which are the subject of this Convention. | 
