ARTICLE 16
Artistes and Athletes
1. Notwithstanding the provisions of Article 14, income derived by a resident of a Contracting State as an entertainer, such as a theatre, motion picture, radio or television artiste, or a musician, or as an athlete, from his personal activities as such exercised in the other Contracting State, may be taxed in that other State.
2. Where income in respect of personal activities exercised by an entertainer or an athlete in his capacity as such accrues not to the entertainer or athlete himself but to another person, that income may, notwithstanding the provisions of Articles 7 and 14, be taxed in the Contracting State in which the activities of the entertainer or athlete are exercised.
3. The provisions of paragraphs 1 and 2 of this Article shall not apply to remuneration or profits, salaries, wages and other similar income derived from activities performed by an entertainer or athlete, or provided by an enterprise of a Contracting State, in a Contracting State if the visit to that Contracting State, or the enterprise, as the case may be, is substantially supported by public funds of the other Contracting State, including any local authority or statutory body thereof.
ARTICLE 17
Pensions
Subject to the provisions of paragraph 2 of Article 18, pensions and other similar remuneration paid to a resident of a Contracting State in consideration of past employment shall be taxable only in that State.
ARTICLE 18
Governmental Function
1. a) Remuneration, other than a pension, paid by a Contracting
State or a political subdivision or a local authority thereof to
an individual in respect of services rendered to that State or
political subdivision or local authority shall be taxable only in
that State.
b) However, such remuneration shall be taxable only in the
other Contracting State if the services are rendered in that
State and the individual is a resident of that State who:
(i) is a national of that State; or
(ii) did not become a resident of that State solely for the
purpose of rendering the services.
2. a) Any pension paid by, or out of funds created by, a Contracting
State or a political subdivision or a local authority thereof to
an individual in respect of services rendered to that State or
political subdivision or local authority shall be taxable only in
that State.
b) However, such pension shall be taxable only in the other
Contracting State if the individual is a resident of, and a
national of, that State.
3. The provisions of Articles 14, 15 and 17 shall apply to remuneration and pensions in respect of services rendered in connection with a business carried on by a Contracting State or a political subdivision or a local authority thereof.
ARTICLE 19
Students
1. An individual who, immediately before visiting a Contracting State, was a resident of the other Contracting State and whose visit to the first-mentioned Contracting State is solely for the purpose of:
a) studying at a university or other recognized educational
institution; or
b) securing training to qualify him to practise a profession or
trade; or
c) studying or carrying out research as a recipient of a grant,
allowance or award from a governmental, religious,
charitable, scientific, literary or educational organization;
shall be exempt from tax in the first-mentioned State on:
(i) remittances from abroad for the purposes of his
maintenance, education, study, research or training;
(ii) the grant, allowance or award.
2. With respect to income from personal services rendered in the first-mentioned State, a student described in paragraph 1 shall be entitled during such education or training to the same exemptions, reliefs or reductions in respect of taxes available to residents of the State which he is visiting.
ARTICLE 20
Elimination of Double Taxation
1. The laws in force in either of the Contracting States shall continue to govern the taxation of income in the respective Contracting States except where express provisions to the contrary are made in this Convention.
2. a) Where a resident of Switzerland denies income which, in
accordance with the provisions of this Convention, may be
taxed in Thailand, Switzerland shall, subject to the
provisions of sub-paragraph b), exempt such income from
tax but may, in calculating tax on the remaining income of
that resident, apply the rate of tax which would have been
applicable if the exempted income had not been so
exempted. Provided, however, that where income or profits
derived by an enterprise which is a resident of Switzerland
from sources within Thailand which in accordance with
paragraph 2 of Article 8 or paragraph 5 of Article 13 are
subject to tax in Thailand, the Swiss tax charged on such
income, or profits shall be reduced by one half.
b) Where a resident of Switzerland derives dividends, interest or
royalties which, in accordance with the provisions of Article
10, 11 or 12, may be taxed in Thailand, Switzerland shall
allow, upon request, a relief to such resident. The relief may
consist of:
(i) a deduction from the tax on the income of that
resident of an amount equal to the tax levied in
Thailand in accordance with the provisions of Article
10, 11 or 12; such deduction shall not, however,
exceed that part of the Swiss tax, as computed before
the deduction is given, which is appropriate to the
income which may be taxed in Thailand; or
(ii) a lump sum reduction of the Swiss tax; or
(iii) a partial exemption of such dividends, interest or
royalties from Swiss tax, in any case consisting at
least of the deduction of the tax levied in Thailand from
the gross amount of the dividends, interest or royalties.
Switzerland shall determine the applicable relief and
regulate the procedure inaccordance with the Swiss
provisions relating to the carrying out of international
conventions of the Swiss Confederation for the
avoidance
of double taxation.
c) Where a resident of Switzerland derives interest which, in
accordance with the provisions of sub-paragraph b) of
paragraph 2 of Article 11 may be taxed in Thailand,
Switzerland shall allow, upon request, a relief to such
resident which may consist of:
(i) the deduction of 5 per cent of the gross amount of such
interest, and
(ii) a deduction from the Swiss tax on the income of that
resident, as computed by reference to the relief
referred to in (i), of an amount of 10 per cent of the
gross amount of the interest; such deduction shall,
however, be determined pursuant to the general
principles of relief referred to in paragraph b).
d) Where a resident of Switzerland derives dividends or interest
or royalties which, in accordance with the Investment
Promotion Act (B.E. 2520) or of the Revenue Code (B.E.
2481) or other special incentive laws which are designated
to promote economic development of Thailand, effective on
the date of signature of this Convention, or which may be
introduced hereinafter in modification of or in addition to the
existing laws, are exempt from Thai tax or taxed at a rate
lower than the rate provided for in Article 10, paragraph 2, or
in Article 11, paragraph 2, or Article 12, paragraph 2,
respectively, Switzerland shall allow, upon request, a relief to
such resident of an amount equal to 10 per cent of the gross
amount of the dividends, interest and royalties. In the case of
dividends such relief shall only be allowed if the dividends
are not exempted from Swiss tax under the provision of sub-
paragraph e) of this paragraph.
e) A company which is a resident of Switzerland and which
derives dividends from a company which is a resident of
Thailand shall be entitled for the purposes of Swiss tax with
respect to such dividends, to the same relief which would be
granted for the company if the company paying the dividends
were a resident of Switzerland.
3. In the case of Thailand, Swiss tax payable in respect of income derived from Switzerland shall be allowed as a credit against Thai tax payable in respect of that income. The credit shall not, however, exceed that part of the Thai tax, as computed before the credit is given, which is appropriate to such item of income.
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