CONVENTION BETWEEN THE GOVERNMENT OF THE KINGDOM OF THAILAND AND
THE GOVERNMENT OF THE UNITED KINGDOM OF GREAT BRITAIN
AND NORTHERN IRELAND
FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION
OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME

The Government of the Kingdom of Thailand and the Government of the United Kingdom of Great Britain and Northern Ireland; Desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income;

Have agreed as follows:

Article 1
Personal Scope

This Convention shall apply to persons who are residents of one or both of the Contracting States.

Article 2
Taxes Covered

1. The existing taxes which are the subject of this Convention are:

(a) in the United Kingdom:

(i) the income tax;
(ii) the corporation tax;
(iii) the capital gains tax;
(iv) the development land tax; and
(v) the petroleum revenue tax;
(hereinafter referred to as "United Kingdom tax");

(b) in Thailand:

(i) the income tax; and
(ii) the petroleum tax;
(hereinafter referred to as "Thai tax").

2. The Convention shall also apply to any tax which is subsequently imposed by either Contracting State in addition to, or in place of, the existing taxes provided that it is agreed by the competent authorities of the Contracting States to be identical or substantially similar to the taxes existing at the date of signature of the Convention. The competent authorities of the Contracting States shall notify each other of any changes which are made in their respective taxation laws.

Article 3
General Definitions

1 In this Convention, unless the context otherwise requires:

(a) the term "United Kingdom" means Great Britain and Northern Ireland, including any area outside the territorial sea of the United Kingdom which in accordance with international law has been or may hereafter be designated, under the laws of the United Kingdom concerning the Continental Shelf, as an area within which the rights of the United Kingdom with respect to the sea-bed and subsoil and their natural resources may be exercised;

(b) the term "Thailand" means the Kingdom of Thailand and any area adjacent to the territorial waters of the Kingdom of Thailand which by Thai legislation, and in accordance with international law, has been or may hereafter be designated as an area within which the rights of the Kingdom of Thailand with respect to the sea-bed and subsoil and their natural resources may be exercised;

(c) the term "nationals" means:

(i) in relation to the United Kingdom, citizens of the United Kingdom and Colonies and British subjects not possessing that citizenship or the citizenship of any other Commonwealth country or territory, provided in all cases they are patrial within the meaning of the Immigration Act 1971, and all legal persons, partnerships, associations or other entities deriving their status as such from the law in force in the United Kingdom;

(ii) in relation to Thailand, all individuals possessing the nationality of Thailand and all legal persons, partnerships and associations deriving their status as such from the law in force in Thailand;

(d) The term "tax" means United Kingdom tax or Thai tax, as the context requires;

(e) the terms "a Contracting State" and "the other Contracting State" mean the United Kingdom or Thailand, as the context requires;

(f) the term "person" comprises an individual, a company and any body of persons which is treated as an entity for tax purposes;

(g) the term "company" means any body corporate or any entity which is treated as a body corporate for tax purposes;

(h) the terms "enterprise of a Contracting State" and "enterprise of the other Contracting State" mean respectively an enterprise carried on by a resident of a Contracting State and an enterprise carried on by a resident of the other Contracting State;

Part 2