ARTICLE 26 EXCHANGE OF INFORMATION
1. The competent authorities of the Contracting States shall exchange such information as is necessary for the carrying out of this Convention or for the prevention of fraud or for the administration of the domestic laws of the Contracting States concerning taxes covered by this Convention insofar as the taxation thereunder is in accordance with this Convention. Any information so exchanged shall be treated as secret and shall not be disclosed to any persons other than persons (including a court or administrative body) concerned with the assessment or collection of, or prosecution in respect of, or the determination of appeals in relation to, the taxes which are the subject of the Convention.
2 In no case shall the provisions of paragraph (1) of this Article be construed so as to impose on the competent authority of either Contracting State the obligation:
(a to carry out administrative measures at variance with the
laws or administrative practice prevailing in either
Contracting State;
(b) to supply particulars which are not obtainable under the
laws or in the normal course of the administration of
that or the other Contracting State;
(c) to supply information which would disclose any business,
trade, industrial, commercial or professional secret or trade
process, or information, the disclosure of which would be
contrary to public policy.
ARTICLE 27 ENTRY INTO FORCE
1 This convention shall be ratified and the instruments of ratification shall be exchanged at London as soon as possible.
2 This Convention shall enter into force immediately after the expiration of thirty days following the date on which the instruments of ratification are exchanged and shall thereupon have effect:
(a) in the United Kingdom :
(i) in respect of income tax and capital gains tax, for any
year of assessment beginning on or after 6th April
of the calendar year in which this Convention enters
into force;
(ii) in respect of corporation tax, for any financial year
beginning on or after 1st April of the calendar year in
which this Convention enters into force;
(iii) in respect of petroleum revenue tax, for any
chargeable period beginning on or after 1st
January of the calendar year in which this
Covention enters into force; and
(iv) in respect of development land tax, for any realized
development value accruing on or after 1st April of
the calendar year in which this Convention enters
into force;
(b) in Thailand:
in respect of Thai tax for taxable years and accounting
periods beginning on or after 1st January of the calendar
year in which this Convention enters into force.
ARTICLE 28 TERMINATION
This Convention shall remain in force until terminated by one of the Contracting States. Either Contracting State may terminate the Convention, through the diplomatic channel, by giving notice of termination at least six months before the end of any calendar year beginning on or after the expiration of a period of five years from the date of its entry into force. In such event, the Convention shall cease to have effect:
(a) in the United Kingdom:
(i) in respect of income tax and capital gains tax, for any
year of assessment beginning on or after 6th April in
the calendar year next following that in which the
notice is given;
(ii) in respect of corporation tax, for any financial year
beginning on or after 1st April in the calendar year
next following that in which the notice is given;
(iii) in respect of petroleum revenue tax, for any
chargeable period beginning on or after 1st January
in the year next following that in which the notice is
given; and
(iv) in respect of development land tax, for any realized
development value accruing on or after 1st April in the
year next following that in which the notice is given;
(b) in Thailand:
in respect of Thai tax, for taxable years and accounting
periods beginning after the end of the calendar year in which
the notice is given.
IN WITNESS WHEREOF the undersigned, duly authorized thereto by their respective Governments, have signed this Convention.
DONE in duplicate at Bangkok this eighteenth day of February in the year nineteen hundred and eighty-one in the Christian Era corresponding to the two thousand five hundred and twenty-fourth year in the Buddhist Era in the English and Thai languages, both texts being equally authoritative.
FOR THE GOVERNMENT OF THE UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND Peter Tripp (Peter Tripp) Ambassador | FOR THE GOVERNMENT OF THE KINGDOM OF THAILAND Air Chief Marshal Siddhi Savetsila (Siddhi Savetsila) Minister of Foreign Affairs |
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