ARTICLE 16
DIRECTORS' FEES AND REMUNERATION OF
TOP-LEVEL MANAGERIAL OFFICIALS

1.         Directors’ fees and other similar payments derived by a resident of a Contracting State in his capacity as a member of thre Board of Directors of a company which is a resident of the other Contracting State may be taxed in that other State.

2.         Salaries, wages and other similar remuneration derived by a resident of a Contracting State in his capacity as an official in a top-level managerial position of a company which is a resident of the other Contracting State may be taxed in that other State.

ARTICLE 17
ARTISTES AND ATHLETES

1.         Notwithstanding the provisions of Article 14 and 15, income derived by public entertainers, such as theatre, motion picture, radio or television artistes, and musicians, and by athletes, from their personal activities as such may be taxed in the Contracting State in which these activities are performed.

2.         Where income in respect of personal activities exercised by an entertainer or an athlete in his capacity as such accrues not to the entertainer or athlete himself but to another person, that income may, notwithstanding the provisions of Article 7, 14 and 15, be taxed in the Contracting State in which the activities of the entertainer or athlete are exercised.

3.         Notwithstanding the provisions of Article 7, where the activities mentioned in paragraph 1 of this Article are provided in a Contracting State by an enterprise of the other Contracting State the profits derived from providing these activities by such an enterprise may be taxed in the first-mentioned Contracting State unless the enterprise is substantially supported by the public funds of the other Contracting State, including any political subdivision, local authority or statutory body thereof, in connection with the provisions of  such activities.

4.         The provisions of paragraphs 1 and 2 of this Article shall not apply to remuneration or profits, salaries, wages and similar income derived from activities performed in a Contracting State by public entertainers or athletes if the visit to that Contracting State is substantially supported by public funds of the other Contracting State, including any political subdivision, local authority or statutory body thereof.

ARTICLE 18
GOVERNMENTAL FUNCTIONS

1.         Remuneration (not being a pension) paid by the Government of a Contracting Sate to any individual who is a citizen of that State in respect of services rendered in the discharge of governmental functions in the other Contracting State shall be taxable only in the first-mentioned Contracting State.

2.         Any pension paid by the Government of one of the Contracting States to any individual may be taxed in that Contracting State.

3.         The provisions of paragraphs 1 and 2 shall not apply to remuneration and pensions in respect of services rendered in connection with any business carried on by the Government of either of The Contracting State for the purposes of profit.

4.         For the purposes of this Article, the term "Government" shall include any State Government or local or statutory authority of either Contracting State and in particular the Reserve Bank of India and the Bank of Thailand.

ARTICLE 19
NON-GOVERNMENT PENSIONS AND ANNUITIES

1.         Any pension (other than a pension referred to in Article 18) or annuity derived by a resident of a Contracting State from sources within the other Contracting State may be taxed only in the first-mentioned Contracting State.

2.         The term “pension” means a periodic payment made in consideration of services rendered in the past or as compensation for injuries received in the course of performance of services.

3.         The term “annuity” means a stated sum payable periodically at stated times, during life or during a specified or ascertainable period of time, under an obligation to make the payments in return for adequate and full consideration in money or money’s worth.

ARTICLE 20
STUDENTS AND APPRENTICES

1.           A student or business apprentice 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 be exempt from tax in the first-mentioned Contracting State on:

             (a)        the grant, allowance or award for the purposes of his

                          maintenance, education or training;

             (b).       payments made to him by persons residing outside that

                          first- mentioned Contracting State for the purposes of his

                          maintenance, education or training; and

             (c)        remuneration from employment in that first-mentioned

                          Contracting State, in an amount not in excess of Rs.15,000

                          or its equivalent in Thai currency during any “previous year”

                          or “tax year”, as the case may be, provided that such

                          employment is directly related to his studies or is

                          undertaken for the purpose of his maintenance.

2.         The term "pension" means a periodic payment made in consideration of serices rendered in the past or as compensation for injuries received in the course of performance of services.

3.         The term "annuity" means a stated sum payable periodically at stated times, during life or during a specified or ascertainable period of time, under an obligation to make the payments in return for adequate and full consideration in money or money's worth.

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