Article 29 - Termination - Thailand (Old - Effective upto 31-3-2016)

Article 29 : Termination This Convention shall remain in force indefinitely but either Contracting State may terminate the Convention, through diplomatic channels, by giving to the other Contracting State, written notice of termination on or before June 30th of any calendar year after the expiration of five years from the year in which the Convention entered into force. In such event, the Convention shall cease to have effect : (a) in India, in respect of income derived during the "previous years" beginning on or after the first day of January of the calendar year next following the calendar year in which the notice is given; (b) in Thailand, in respect of income derived during "tax years" or "accounting periods" beginning on or after the first day of January of the calendar year next following the calendar year in which the notice is given. IN WITNESS WHEREOF the undersigned, duly authorised thereto by their respective Governments, have signed this Convention. Done at New Delhi on this 22nd day of March, one thousand nine hundred and eighty-five, in six originals, two each in the Hindi, Thai and English languages, all texts being equally authentic, except in case of divergence when the English text shall prevail. (Vishwanath Pratap Singh) Minister of Finance For the Government of the Republic of India (Siddhi Savetsila) Air Chief Marshal Minister of Foreign Affairs For the Government of the Kingdom of Thailand Memorandum of understanding with respect to the Double Taxation Convention between the Kingdom of Thailand and the Republic of India. It is understood that : 1. The term "tax" as defined in paragraph 1(d) of Article 3 of this Convention shall be interpreted not to include any amount which is payable in respect of any default or omission in relation to the taxes to which this Convention applies or which represents a penalty imposed relating to those taxes. 2. Nothing in paragraph 5 of Article 10 of this Convention shall be construed so as to prevent Thailand from imposing tax on the disposal of profits (not in the form of dividends) in accordance with section 70 bis of the Thai Revenue Code. 3. With reference to paragraph 2 of Article 26, any agreement reached by the two competent authorities shall be implemented notwithstanding any time-limits in the domestic laws of the Contracting States provided that the implementation of such agreement will be beneficial to the tax payer concerned. 4. In case Thailand grants reduction from tax of an amount more than 50 per cent thereof on income derived from the operation of ships in international traffic by a resident of any country, paragraph 2 of Article 8 of the Convention shall be reconsidered with a view to granting, on the basis of reciprocity, the same reduction from tax on such income of shipping companies which are residents of India. (Vishwanath Pratap Singh) Minister of Finance For the Government of the Republic of India (Siddhi Savetsila) Air Chief Marshal Minister of Foreign Affairs For the Government of the Kingdom of Thailand Notification No. 6780 [F. No. 145/4/71-FTD]