ARTICLE 26
EXCHANGE OF INFORMATION
1. The competent authorities of the Contracting States shall exchange such information as is necessary for carrying out the provisions of this Agreement or of the domestic laws of the Contracting States concerning taxes covered by the Agreement insofar as the taxation thereunder is not contrary to the Agreement. Any information received by a Contracting State shall be treated as secret in the same manner as information obtained under the domestic laws of that Contracting State and shall be disclosed only to persons or authorities (including courts and administrative bodies) involved in the assessment or collection of, the enforcement or prosecution in respect of, or the determination of appeals in relation to, the taxes covered by the Agreement. Such persons or authorities shall use the information only for such purposes. They may disclose the information in public court proceedings or in judicial decisions.
2. In no case shall the provisions of paragraph 1 by construed so as to impose on a Contracting State the obligation:
(a) to carry out administrative measures at variance with the
lawsand administrative practice of that or of the other
Contracting State;
(b) to supply information which is not obtainable under the laws
or in the normal course of the administration of that or of the
other Contracting State;
(c) to supply information which would disclose any trade,
business, industrial, commercial or professional secret or
trade process, or information, the disclosure of which would
be contrary to public policy (ordre public).
ARTICLE 27
DIPLOMATIC AGENTS AND CONSULAR OFFICIALS
Nothing in this Agreement shall affect the fiscal privileges of diplomatic agents or consular officials under the general rules of international law or under the provisions of special agreements.
ARTICLE 28
ENTRY INTO FORCE
1. This Agreement shall enter into force on the thirtieth day after the date on which diplomatic notes indicating the completion of internal legal procedures necessary in each country for the entry into force of this Agreement have been exchanged.
2. This Agreement shall have effect:
(a) in respect of taxes withheld at the source, on amounts paid
or remitted on or after the first day of January next following
that in which the exchange of diplomatic notes takes place;
(b) in respect of other taxes on income, for taxable years or
accounting periods beginning on or after the first day of
January next following that in which the exchange
ofdiplomatic notes takes place.
ARTICLE 29
TERMINATION
This Agreement shall remain in force indefinitely, but either of the Contracting States may, on or before 30th June in any calendar year beginning after the expiration of a period of five years from the date of its entry into force, give to the other Contracting State, through diplomatic channels, written notice of termination.
In such event the Agreement shall cease to have effect:
(a) in respect of taxes withheld at the source, on amounts paid
or remitted on or after the first day of January next following
that in which the notice is given;
(b) in respect of other taxes on income, for taxable years or
accounting periods beginning on or after the first day of
January next following that in which the notice is given.
IN WITNESS WHEREOF, the undersigned duly authorized thereto, have signed this Agreement.
DONE in duplicate at Bangkok on this 27th day of October, one thousand nine hundred and eighty-six Year of the Christian Era, each in the Thai, Chinese and English languages, all texts being equally authoritative, except in the case of doubt when the English text shall prevail.
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