Common use of METHODS FOR ELIMINATION OF DOUBLE TAXATION Clause in Contracts

METHODS FOR ELIMINATION OF DOUBLE TAXATION. 1. Subject to the provisions of the laws of the Hong Kong Special Administrative Region relating to the allowance of a credit against Hong Kong Special Administrative Region tax of tax paid in a jurisdiction outside the Hong Kong Special Administrative Region (which shall not affect the general principle of this Article), Thai tax paid under the laws of Thailand and in accordance with this Agreement, whether directly or by deduction, in respect of income derived by a person who is a resident of the Hong Kong Special Administrative Region from sources in Thailand, shall be allowed as a credit against Hong Kong Special Administrative Region tax payable in respect of that income, provided that the credit so allowed does not exceed the amount of Hong Kong Special Administrative Region tax computed in respect of that income in accordance with the tax laws of the Hong Kong Special Administrative Region. 2. Subject to the laws of Thailand regarding the allowance as a credit against Thai tax of tax paid in any country other than Thailand, Hong Kong Special Administrative Region tax paid in respect of income derived from Hong Kong Special Administrative Region shall be allowed as a credit against Thai tax paid in respect of that income. The amount of credit shall not, however, exceed that portion of Thai tax which is appropriate to that income. 3. For the purpose of allowance as a credit in a Contracting Party the tax paid in the other Contracting Party shall be deemed to include the tax which is otherwise payable in that other Contracting Party but has been reduced or waived in accordance with special incentive laws designed to promote economic development in that other Contracting Party. The provisions of this paragraph shall only apply for a period of 7 years from the day on which this Agreement comes into effect according to paragraph 2 of Article 27. The periods may be extended by mutual agreement between the competent authorities.

METHODS FOR ELIMINATION OF DOUBLE TAXATION. 1. Subject to the provisions of the laws of the Hong Kong Special Administrative Region relating to the allowance of a credit against Hong Kong Special Administrative Region tax of tax paid in a jurisdiction outside the Hong Kong Special Administrative Region (which shall not affect the general principle of this Article), Thai tax paid under the laws of Thailand and in accordance with this Agreement, whether directly or by deduction, in respect of income derived by a person who is a resident of the Hong Kong Special Administrative Region from sources in Thailand, shall be allowed as a credit against Hong Kong Special Administrative Region tax payable in respect of that income, provided that the credit so allowed does not exceed the amount of Hong Kong Special Administrative Region tax computed in respect of that income in accordance with the tax laws of the Hong Kong Special Administrative Region.Region.‌ 2. Subject to the laws of Thailand regarding the allowance as a credit against Thai tax of tax paid in any country other than Thailand, Hong Kong Special Administrative Region tax paid in respect of income derived from Hong Kong Special Administrative Region shall be allowed as a credit against Thai tax paid in respect of that income. The amount of credit shall not, however, exceed that portion of Thai tax which is appropriate to that income.income.‌ 3. For the purpose of allowance as a credit in a Contracting Party the tax paid in the other Contracting Party shall be deemed to include the tax which is otherwise payable in that other Contracting Party but has been reduced or waived in accordance with special incentive laws designed to promote economic development in that other Contracting Party. The provisions of this paragraph shall only apply for a period of 7 years from the day on which this Agreement comes into effect according to paragraph 2 of Article 27. The periods may be extended by mutual agreement between the competent authorities.authorities.‌