ARTICLE 21
Professors, teachers and researchers 1. An individual who is or was immediately before visiting a Contracting State a resident of 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 the first·mentioned Contracting State, visits that first·mentioned 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. The provisions of paragraph 1 shall not apply to income from research if such research is undertaken by the individual primarily for the private benefit of a specific person or persons. ARTICLE 22
Activities in Connection with Preliminary Surveys,
Exploration or Extraction of Hydrocarbons 1. Notwithstanding the provisions of Articles 5 and 14, a resident of a Contracting State who carries on activities in connection with preliminary surveys, exploration or extraction of hydrocarbons situated in the other Contracting State shall be deemed to be carrying on in respect of such activities a business in that other Contracting State through a permanent establishment or fixed base situated therein. 2. The provisions of paragraph 1 shall not apply where the activities are carried on for a period or periods not exceeding 30 days in aggregate in any twelve month period. However, for the purpose of this paragraph, activities carried on by an enterprise associated with another enterprise within the meaning of Article 9 shall be regarded as carried on by the enterprise with which it is associated if the activities in question are substantially the same as those carried on by the last·mentioned enterprise. 3. Notwithstanding the provisions of paragraphs 1 and 2, drilling rig activities carried on offshore shall constitute a permanent establishment only if the activities are carried on for a period or periods exceeding 183 days in aggregate in any twelve month period. However, for the purpose of this paragraph, activities carried on by an enterprise associated with another enterprise within the meaning of Article 9 shall be regarded as carried on by the enterprise with which it is associated if the activities in question are substantially the same as those carried on by the last-mentioned enterprise. ARTICLE 23
Other Income 1. Items of income of a resident of a Contracting State, wherever arising, not dealt with in the foregoing Articles of this Convention shall be taxable only in that State. 2. The provisions of paragraph 1 shall not apply to income, other than income from immovable property as defined in paragraph 2 of Article 6, if the recipient of such income, being a resident of a Contracting State, carries on business in the other Contracting State through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the income is paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 3. Notwithstanding the provisions of paragraphs 1 and 2, items of income of a resident of a Contracting State not dealt with in the foregoing Articles of this Convention and arising in the other Contracting State may also be taxed in that other State. ARTICLE 24
Elimination of Double Taxation 1. The laws in force in either of the Contracting States shall continue to govern the taxation of income in the respective Contracting States except when an express provision to the contrary is made in this Convention. When income is subject to tax in both Contracting States, relief from double taxation shall be given in accordance with the following paragraphs of this Article. 2. In Denmark: (a) Subject to the provisions of sub·paragraph (c), where a resident of Denmark derives income which, in accordance with the provisions of this Convention, may be taxed in Thailand, Denmark shall allow as a deduction from the tax on the income of that resident, an amount equal to the income tax paid in Thailand; (b) such deduction shall not, however, exceed that part of the Danish income tax, as computed before the deduction is given, which is attributable to the income which may be taxed in Thailand; (c) where a resident of Denmark derives income which, in accordance with the provisions of this Convention shall be taxable only in Thailand, Denmark may include this income in the tax base, but shall allow as a deduction from the income tax that part of the income tax, which is attributable to the income derived from Thailand. (d) Where exemption from or reduction of Thai tax payable in accordance with the provisions of Article 7 in respect of profits derived by a Danish enterprise from a permanent establishment situated in Thailand has been granted under Thai law, then, for the purposes of sub·paragraph (a) and sub-paragraph (b), deduction from Danish tax for Thai tax shall be allowed as if no such exemption or reduction had been granted, provided the permanent establishment is engaged in business activities (other than business activities in the financial sector) and that no more than 25 per cent of such profits consist of interest and gains from the alienation of shares and bonds or consist of profits derived from third States. (e) Where dividends are paid by a company which is a resident of Thailand to a person (being a company) which is a resident of Denmark, and which owns directly or indirectly not less than 25 per cent of the share capital of the first·mentioned company, then such dividends shall be exempt from tax in Denmark, provided that the company paying the dividends is engaged in business activities (other than business activities in the financial sector) and that no more than 25 per cent of the company's profits consist of interest and gains from the alienation of shares and bonds or consist of profits derived from third States. (f) For the purposes of sub-paragraphs (a) and (b) of this paragraph, in the case of royalties paid as a consideration for the use of, or the right to use, any patent, trade mark, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, and for the use of, or the right to use, industrial, commercial or scientific equipment in connection therewith, Thai tax shall be deemed to be paid at the rate provided for in paragraph 2 of Article 12, where the assets for which the royalties are paid have been used in an activity (other than business activities in the financial sector) which has been carried out in Thailand. However, Thai tax shall in no case be deemed to be paid at a rate exceeding the tax rate applicable to royalties under Thai law.This provision shall not apply where royalties are paid between associated enterprises within the meaning of Article 9 or where royalties are paid in respect of assets which have been sold and leased back by the person paying the royalties. (g) The provisions in sub·paragraphs (d) - (f) shall apply for the first ten years for which the Convention is effective. The competent authorities shall consult each other in order to determine whether this period shall be extended. Any such extension shall take effect from such date and subject to such modifications and conditions, including conditions as to termination, as may be specified and agreed between the Contracting States in notes to be exchanged through diplomatic channels or in any other manner in accordance with their constitutional procedures. 3. In the case of Thailand, Danish tax payable in accordance with this Convention in respect of income from sources within Denmark shall be allowed as a credit against Thai tax payable in respect of that income. The credit shall not, however, exceed that part of the Thai tax, as computed before the credit is given, which is appropriate to such item of income. 4. Where under any provision of this Convention income is relieved from Danish tax and, under the law in force in Thailand, an individual in respect of the said income is subject to tax by reference to the amount thereof which is remitted to or received in Thailand and not by reference to the full amount thereof, then the relief to be allowed under this Convention in Denmark shall apply only to so much of the income as is taxed in Thailand. ARTICLE 25
Non-Discrimination 1. 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, in particular with respect to residence, are or may be subjected. This provision shall, notwithstanding the provisions of Article 1, also apply to persons who are not residents of one or both of the Contracting States. 2. Stateless persons who are residents of a Contracting State shall not be subjected in either 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 the State concerned in the same circumstances, in particular with respect to residence, are or may be subjected. 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. 4. Except where the provisions of paragraph 1 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. 5. 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 the first·mentioned State are or may be subjected. 6. 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. 7. The provisions of this Article shall only apply to the taxes which are the subject of this Convention. | 
