|
Country |
Cambodia |
Lao PDR |
Myanmar |
Thailand |
Vietnam |
Yunnan, China |
|
Number |
|
|
|
|
|
|
|
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. |
|
|
