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 may be taxed in the State where the income arises.

ARTICLE 23
DOUBLE ELIMINATION OF TAXATION

1.         In the case of the Hungarian People’s Republic double taxation shall be eliminated as follows:

            (a)        Where a resident of the Hungarian People’s Republic

                         derives income which, in accordance with the provisions of

                         this Convention, may be taxed in Thailand, the Hungarian

                         People’s Republic, shall subject to the provisions of

                         subparagraphs (b) and (c), exempt such income from tax.

            (b)        Where a resident of the Hungarian People’s Republic

                         derives income which, in accordance with the provisions of

                         Articles 10 and 12, may be taxed in Thailand, the Hungarian

                         People’s Republic shall allow as a deduction from

                         Hungarian 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 Hungarian tax, as computed

                         before the deduction is given, which is attributable to such

                         items of income. For the purposes of this subparagraph, the

                         tax paid in Thailand 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 under the Thai Revenue

                         Code or 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.

            (c)        Where, in accordance with the provisions of this

                         Convention,income derived  by a resident of the Hungarian

                         People’s Republic is exempt from tax in the Hungarian

                         People’s Republic, the Hungarian People’s Republic may,

                         nevertheless in calculating the amount of tax on the

                         remaining income of such resident, take into account the

                         exempted income.

2.         In the case of Thailand, where a resident of Thailand derives income which, in accordance with the provisions of this Convention, may be taxed in the Hungarian People’s Republic, Thailand shall allow as a deduction from Thai tax on the income of that resident an amount equal to the tax paid in the Hungarian People’s Republic. Such deduction shall not, however, exceed that part of the Thai tax, as computed before the deduction is given, which is attributable to such items of income.

ARTICLE 24
NON DISCRIMINATION

1.         Nationals of a Contracting State shall not be subjected in the other Contracting State to any taxation or any requirement connected there which 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. This provisions shall notwithstanding the provisions of Article 1, also apply to persons who are not residents of one or both of the Contracting State.

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 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.         Except where the provisions of Article 9, paragraph 7 of Article 11, or paragraph 6 of Article 12, apply interest, royalties and other disbursements paid by an enterprise of a Contracting State to a resident of the other Contracting State shall, for the purpose of determining the taxable profits of such enterprise, be deductible under the same conditions as if they had been paid to a resident of the first mentioned State.

6.         In this Article the term “taxation” means taxes which are the subject of this Convention.

ARTICLE 25
MUTUAL AGREEMENT PROCEDURE

1.         Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Convention, he may, irrespective of the remedies provided by the domestic laws of those States, present his case to the competent authority of the Contracting state of which he is a resident or, if this case comes under paragraph 1 of Article 24, to that of the Contracting State of which he is a national. The case must be presented within three years from the First notification of the action resulting in taxation not in accordance with the provisions of this Convention.

2.         The competent authority shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State with a view to the avoidance of taxation which is not in accordance with the Convention.

3.         The competent authorities of the Contacting State shall endeavour to resolve by mutual agreement any difficulties or doubts arising as to the interpretation or application of the Convention. They may also consult together for the elimination of double taxation in case not provided for in the Convention.

4.         The competent authorities of the Contracting States may communicate with each other directly for the purposes of reaching an agreement in the sense of the preceding paragraphs.

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