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Class Double Taxation Treaty


Country Cambodia Lao PDR Myanmar Thailand Vietnam Yunnan, China
Treaty Partner Example       USA   USA
Year       1996-Signed   1984
Name       Convention for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion.   Agreement…for the Avoidance of Double Taxation and the Prevention of Tax Evasion
Exclusions       Tax Sparing Credits on Thailand BoI-Promoted Investment Projects   None
Interpretation       Vienna, Convention of 1969 US Court Law   Authority in Country of Residence and/or Consultation between the Countries
Application       Citizens of Signatory Countries plus Former Citizens of Signatory Countries who have deliberately lost Citizenship in Signatory Countries   Residents of one or both of the countries
Unilateral       Retained   Not Stated
Right to Tax            
Taxes Covered       Income Tax only - USA Income Tax plus Petroleum Tax-Thailand   Federal Income Tax Individual Income Tax, JV Income Tax, Tax on Foreign Investment
Taxes not Covered       Social Security Tax-USA   Local Tax
Residency Definition       Not on Source of Income Basis   Resident of one or other Country, excluding third country joint residence for PRC
Permanent       Branch   Branch
Establishment       Office Building Factory Construction Site Drill Rig, Mine   Office Building Factory Construction Site Drill Rig, Mine
Real Estate       Income may be taxed by the Partner country and includes income from agriculture and Forestry   See Thailand-US Treaty
Business       Taxable   See Thailand-US Treaty
Profit       where Enterprise located provided Enterprise is Permanent    
Transport Industry Income       Taxable only in country of Residence   Not Stated
Related Enterprise       Partner Countries have Right to Raise Tax and other Partner Country to Lower Tax Rate   Taxed as if Arms Length
Dividends       Taxable in either Partner country   See Thailand-US Treaty
Interest       Taxable in Country of residence of Interest income recipient   Liable to Taxation in both Countries
Royalties       See Interest Income above   See Interest reference
Professional       Taxable only in Country of Residence unless possessing Permanent Base or stays longer than 90 Days in the Partner Country or if Income exceeds US$10000 or Thai Baht equivalent   See Thailand-US Treaty 183 Days Residency Test
Ownership Test to Qualify for Coverage       At least 50 percent   Includes agents wholly or almost wholly
Pension and like Income       Taxable in Country where such income arises   See Thailand-US Treaty
Government Services       Taxable in Country where it Arises   Not Stated
Partner Countries with Double Taxation Treaties (current to 2002)       USA, Norway, Germany, France, Singapore, Netherlands, South Korea, Italy, Belgium, Pakistan, Indonesia, Malaysia, UK, Philippines, Poland, Canada, Finland, India, Austria, China, Sweden, Hungary, Australia, Sri Lanka, Japan, Vietnam, Czech, Israel, Switzerland, South Africa, Romania, Lao PDR, Mauritius, Luxembourg, Bangladesh, Spain, Nepal, New Zealand, Denmark, Uzbekistan, UAE, Cyprus, Bulgaria.    


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