ARTICLE 26 More favourable domestic law If the law of either Contracting State existing at present or established hereafter contains a regulation entitling a resident of a Contracting State to a treatment more favourable than is provided for by this Convention, such regulation shall, to the extent that it is more favourable, not be affected by this Convention. ARTICLE 27 Diplomatic and Consular Officials Nothing in this Convention shall affect the fiscal privileges of diplomatic or consular officials under the general rules of international law or under the provisions of special agreements. CHAPTER VI Final provisions
ARTICLE 28 Entry into force 1. This Convention shall be ratified and the instruments of ratification shall be exchanged at Rome as soon as possible. 2. The Convention shall enter into force on the date of the exchange of instruments of ratification and is provisions shall be effective in respect of income or profits assessable for the taxable year or accounting period commencing on or after the first January 1978. 3. Claims for refund or credits arising in accordance with this Convention in respect of any tax payable by residents of any of the Contracting State shall be lodged within two years from the date of entry into force of this Convention or from the date the tax was paid, whichever is later. ARTICLE 29 Termination This Convention shall remain in force until denounced by one of the Contracting States. Either Contracting State may denounce the Convention, through diplomatic channels, not earlier than five years after its entry into force by giving notice of termination at least six months before the end of the calendar year. In such event, the Convention shall case to be effective in respect of income or profits assessable for the taxable year or accounting period commencing on or after the first January in the calendar year next following that in which the notice of termination is given. IN WITNESS WHEREOF the undersigned, duly authorised thereto, have signed the present Convention. Done in duplicate at Bangkok on the day of 22nd December, 1977 in the English, ltalian and Thai languages, all texts being equally authoritative, except in the case of doubt when the English text shall prevail. For the Government of Thailand: Wongse Polnikorn (Wongse Polnikorn) Deputy Minister of Foreign Affairs | For the Government of Italy: Mario Prunas (Mario Prunas) Ambassador |
PROTOCOL At the time of signing the Convention between The Kingdom of Thailand and The Republic of Italy for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income the undersigned have agreed that the following provisions shall form an integral part of the Convention. It is understood that with reference to Articles 10 and 11 the term "industrial undertaking" means an undertaking falling under any of the classes mentioned below: (1) manufacturing, assembling and processing; (2) construction, civil engineering and shipbuilding; (3) electricity, hydraulic power, gas and water supply; (4) plantation, agriculture, forestry and fishery; and (5) any other undertaking which may be declared to be an "industrial undertaking" for the purpose of these articles by the competent authorities of the Contracting State in which the undertaking is situated. For the Government of Thailand: Wongse Polnikorn (Wongse Polnikorn) Deputy Minister of Foreign Affairs | For the Government of Italy: Mario Prunas (Mario Prunas) Ambassador |
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