ARTICLE 26
Nothing in this Convention shall affect the fiscal privileges of diplomatic agents or consular officers under the general rules of international law or under the provisions of special agreements.
ARTICLE 27 1. The Governments of the Contracting States shall notify each other that the constitutional requirements for the entry into force of this Convention have been complied with.
2. The Convention shall enter into force thirty days after the date of the later of the notifications referred to in paragraph 1 and its provisions shall have effect: a) in Finland: (i) in respect of taxes withheld at source, to income derived on or after the first day of January in the calendar year next following the year in which the Convention enters into force; (ii) in respect of other taxes on income, to taxes chargeable for any taxable year beginning on or after the first day of January in the calendar year next following the year in which the Convention enters into force; b) in Thailand: (i) in respect of withholding taxes, on amounts payable on or after the first day of January in the calendar year next following the year in which the Convention enters into force; (ii) in respect of other taxes, for tax years or accounting periods beginning on or after the first day of January in the calendar year next following the year in which the Convention enters into force.
ARTICLE 28 This Convention shall remain in force until terminated by a Contracting State. Either Contracting State may terminate the Convention, through diplomatic channels, by giving notice of termination at least six months before the end of any calendar year following after the period of five years from the date on which the Convention enters into force. In such event, the Convention shall cease to have effect: a) in Finland: (i) in respect of taxes withheld at source, to income derived on or after the first day of January in the calendar year next following the year in which the notice if given; (ii) in respect of other taxes on income, to taxes chargeable for any taxable year beginning on or after the first day of January in the calendar year next following the year in which the notice is given; b) in Thailand; (i) in respect of withholding taxes, on amounts payable on or after the first day of January in the calendar year next following that in which the notice is given; and (ii) in respect of other taxes, for tax years or accounting periods beginning on or after the first day of January in the calendar year next following that in which the notice is given.
In witness whereof the undersigned, duly authorised thereto, have signed this Convention. Done in duplicate at Bangkok this twenty-fifth day of April 1985, in the English language.
At the moment of signing the Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, this day concluded between the Government of the Kingdom of Thailand and the Government of the Republic of Finland, the undersigned have agreed that the following provisions shall form an integral part of the Convention.
Ad Article 5 It is agreed that for the purpose of paragraph 6 of Article 5, the term substantially is understood to mean that the person s activities for enterprises other than those referred to therein are of such minor importance as compared with his activities for the enterprises mentioned therein that for all practical purposes such person may be regarded as working solely for the latter enterprises.
Ad Article 5 and Article 6 It is understood that a farm or plantation shall, in the case of Thailand, for the purposes of Article 7 of the Convention be regarded as a permanent establishment referred to in Article 5 of the Convention. Under Finnish tax law income from agriculture or forestry is treated as income from immovable property. Accordingly, income from agriculture or forestry carried on in Finland shall, for the purposes of the Convention, be treated as income from immovable property referred to in Article 6 of the Convention.
Ad Article 17 In order to obtain the benefit referred to in paragraph 4 of Article 17, evidence of substantial support shall in case of doubt be presented in the State in which the activities are performed, as agreed upon by mutual agreement by the competent authorities of the Contracting States. In the case of Thailand, the concept of public funds includes money from charitable organisations or institutions.
In witness whereof the undersigned, duly authorised thereto, have signed this Protocal. Done in duplicate at Bangkok this Twenty-Fifth day of April 1985, in the English Language.
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