1. Interest arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such interest may be taxed in the Contracting State in which it arises, and according to the law of that State but the tax so charged shall not exceed: (a) 10 per cent of the gross amount of the interest which is paid to a financial institution (including an insurance company); (b) 25 per cent of the gross amount of all other interest. 3. Notwithstanding the provisions of paragraph 2, a Contracting State shall be exempt from tax in the other Contracting State with respect to interest derived from sources in that other Contracting State. For the purposes of this paragraph, the term Contracting State (a) in the case of Belgium means the Government of the Kingdom of Belgium and shall include: (1) any political subdivision or local authority of Belgium; (2) The National Bank of Belgium; and (3) such institutions, the capital of which is wholly owned by the Government of the Kingdom of Belgium or the political subdivisions or local authorities of Belgium as may be agreed from time to time between the competent authorities of both Contracting States; (b) in the case of Thailand means the Government of the Kingdom and shall include : (1) any local authority of Thailand; (2) the Bank of Thailand; and (3) such institutions, the capital of which is wholly owned by the Government of the Kingdom of Thailand or the local authorities of Thailand, as may be agreed from time to time between the competent authorities of both Contracting States. 4. The term interest as used in this Article means income from debt-claims of every kind, whether or not secured by mortgage, and whether or not carrying a right to participate in the debtors profits, and in particular, income from government securities and income from bonds or debentures, including premiums and prizes attaching to bonds or debentures. However, the term interest does not include for the purpose of this Article, penalty charges for late payment, not interest treated as dividends under paragraph 3 of Article 10. 5. The provisions of paragraphs 1 and 2 shall not apply if the recipient of the interest, being a resident of a Contracting State, carries on business in the other Contracting State in which the interest arises, through a permanent establishment situated therein, or performs in that other State professional services from a fixed base situated therein, and the debt-claim in respect of which the interest is paid is effectively connected with such permanent establishment or fixed base. In such a case, the provisions of Article 7 or Article 14, as the case may be, shall apply. 6. Interest shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a resident of that State. Where, however, the person paying the interest, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the indebtedness on which the interest is paid was incurred, and such interest is borne by such permanent establishment, then such interest shall be deemed to arise in the Contracting State on which the permanent establishment is situated. 7. Where, owing to a special relationship between the payer and the recipient or between both of them and some other person, the amount of the interest paid, having regard to the debt-claim for which it is paid, exceeds the amount which would have been agreed upon by the payer and the recipient in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In that case, the excess of the interest may be taxed in the Contracting State in which the interest arises according to the law of that State.
1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However such royalties may be taxed in the Contracting State in which they arise and according to the law of that State, but if the recipient is the beneficial owner of the royalties, the tax so charged shall not exceed: (a) 5 per cent of the gross amount of the royalties if they are paid as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work; (b) 15 per cent of the gross amount of the royalties if they are paid as a consideration for the use of, or the right ot use, any patent, trade mark, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, cinematograph films and tapes for television or broadcasting. 3. The provisions of paragraphs 1 and 2 shall not apply if the recipient of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State, in which the royalties arise, through a permanent establishment situated therein, or performs in that other State professional services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such a case, the provisions of Article 7 or Article 14, as the case may be, shall apply. 4. Royalties shall be deemed to arise in a Contracting State when the payer is that Contracting State itself , a political subdivision, a local authority or a resident of that Contracting State. Where, however, the person paying the royalties, whether he is resident of a Contracting state or not, has in a Contracting State a permanent establishment in connection with which the liability to pay the royalties was incurred, and the royalties was incurred, and the royalties are borne by such permanent establishment, then the royalties shall be deemed to arise in the Contracting State in which the permanent establishment is situated. 5. Where, owing to a special relationship between the payer and the recipient or between both of them and some other person, the amount of the royalties paid, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the recipient in the absence of such relationship, the provisions of this Article shall apply only to the last - mentioned amount. In that case, the excess part of the royalties may be taxed in the Contracting State in which the royalties arise, according to the law of that State. 6. The provisions of this Article shall likewise apply to the gains from the alienation of any right or property giving rise to royalties as mentioned in paragraph 2.
1. Gains from the alienation of immovable property, as defined in paragraph, 2 of Article 6 may be taxed in the Contracting State in which such property is situated. 2. Gains from the alienation of movable property forming part of the business property of a permanent establishment which an enterprise of a Contracting State has in the other Contracting State or of movable property pertaining to a fixed base available to a resident of a Contracting State in the other Contracting State for the purpose of performing professional services, including such gains from the alienation of such a permanent establishment (alone or together with the whole enterprise) or of such a fixed base, may be taxed in the other State. However, gains from the alienation of movable property of the kind referred to in paragraph 3 of Article 22 shall be taxable only in the Contracting State in which such movable property is taxable according to the said Article. 3. Subject to the provisions of Article 12, gains from the alienation of any property other than those mentioned in paragraphs 1 and 2, shall be taxable only in the Contracting State of which the alienator is a resident.
1. Subject to the provisions of Articles 15, 17, 18, 19 and 20, salaries, wages and other similar remuneration or income derived by a resident of a Contracting State in respect of personal (including professional) services shall be taxable only in that State unless the services are rendered in the other Contracting State. If the services are so rendered, such remuneration or income as is derived therefrom may be taxed in that other State. 2. Notwithstanding the provisions of paragraph 1, remuneration or income derived by a resident of a Contracting state in respect of services rendered in the other Contracting State shall be taxable only in the first-mentioned State if: (a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the fiscal year concerned, and (b) the services are rendered for or on behalf of a person who is resident of the first-mentioned State, and (c) the remuneration or income is not deducted from any profits taxable in the other State. 3. Notwithstanding the preceding provisions of this Article, remuneration in respect of an employment exercised aboard a ship or aircraft in international traffic shall be taxable only in the Contracting State in which the place of effective management of the enterprise is situated.
1. Directors fees and similar payments derived by a resident of a Contracting State in his capacity as a member of the board of directors or a similar organ of a company which is a resident of the other Contracting State may be taxed in that other State. 2. The remuneration which a person to whom paragraph 1 applies derives from the company in respect of the discharge of day-to-day functions of a managerial or technical nature may be taxed in accordance with the provisions of Article 14.
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