ARTICLE 21
PROFESSORS, TEACHERS AND RESEARCHERS

            A resident of a Contracting State who, at the invitation of a university, college or other establishments owned by the other Contracting State or by any non-profit organization, visits that other State solely for the purpose of teaching or scientific research at such institution for a period not exceeding two years shall not be taxed in that other State on his remuneration for such teaching or research.

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
METHOD FOR ELIMINATION OF DOUBLE TAXATION

            Double taxation shall be avoided in the following manner:

1.         In the case of France:

            a)         Income other than that mentioned in subparagraph (b) below

                         shall be exempt from the French taxes mentioned in

                         subparagraph (3) (b) of Article 2 if the income is taxable in

                         Thailand under the Conventionand the law of Thailand.

            b)         As regards income mentioned in Articles 8, 10. 11, 12,16 and

                         17 which has borne the Thai tax in accordance with the

                         provisions of these Articles, France shall allow to a resident

                         of France receiving such income from Thailand a tax credit

                         corresponding to the amount of tax levied in Thailand,

                         provided that in the case of dividends referred to in Article 10

                         the credit shall not exceed 25 per cent of the gross amount

                         thereof. Such tax credit, not exceeding the amount of French

                         tax levied on such income, shall be allowed against the

                         taxes mentioned in subparagraph (3) (b) of Article 2, in the

                         bases of which such income is included.

            c)         Notwithstanding the provisions of subparagraph (a) and (b)

                        French tax may be computed on income chargeable in

                        France by virtue of this Convention at the rate appropriate to

                        the total of the income chargeable in accordance with French

                        law.

2.         In the case of Thailand:

            a)         Income other than that mentioned in subparagraph (b) below

                         shall be exempt from the Thai taxes mentioned in

                         subparagraph (3) (b) of Article 2 if the  income is taxable in

                         France under the Convention and under the law of France.

            b)         As regards income mentioned in Articles 8, 10, 11, 12, 16

                         and 17 which has borne the French tax in accordance with

                         the provisions of these Articles, Thailand shall allow to a

                         resident of Thailand receiving such income from France a

                         credit against Thai tax. Such credit shall be based on the

                         amount of tax paid to France but shall not exceed the portion

                         of Thai tax which net income from sources within France

                         bears to the entire net income subject to Thai tax. In

                         determining such entire net income a loss incurred in any

                         country shall not be taken into account.

            c)         Notwithstanding the provisions of subparagraphs (a) and (b)

                        Thai tax may be computed on income chargeable in Thailand

                         by virtue of this Convention at the rate appropriate to the total

                         of the income chargeable in accordance with Thai law.

ARTICLE 24
NON - DISCRIMINATION

1.         The 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 term “nationals” means:

            a)                  all individuals possessing the nationality of a

                                  Contracting State;

            b)                  all legal persons, partnerships and associations

                                  deriving their status as such from the law in force in a

                                  Contracting State.

3.         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.

This provision 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.

4.         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 that first-mentioned State are or may be subjected.

5.         In this Article, the term “taxation” means taxes of every kind and description.

ARTICLE 25
MUTUAL AGREEMENT PROCEDURE

1.         Where a resident of a Contracting State considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with this Convention, he may, notwithstanding the remedies provided by the national laws of those States, present his case to the competent authority of the Contracting State of which he is a resident.

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 an appropriate 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 not in accordance with the Convention.

3.         The competent authorities of the Contracting States shall endeavour to resolve by mutual agreement any difficulties arising as to the application of the Convention. They may also consult together for the elimination of double taxation in cases not provided for in the Convention.

4.         The competent authorities of the Contracting States may communicate with each other directly for the purpose of reaching an agreement in the sense of the preceding paragraphs. When it seems advisable in order to reach agreement to have an oral exchange of opinions, such exchange may take place through a Commission consisting of representatives of the competent authorities of the Contracting States.

5.         The competent authorities shall settle the mode of application of this Convention.

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