On 15 October 2014, Ireland approved for ratification the pending income and capital gains tax treaty with Thailand. The treaty, signed 4 November 2013, is the first of its kind between the two countries.
The treaty covers Irish income tax, corporation tax and capital gains tax, and Thai income tax and petroleum income tax.
The treaty includes the provision that a permanent establishment will be deemed constituted when an enterprise furnishes services within a Contracting State through employees or other engaged personnel for the same or connected project for a period or periods aggregating more than 6 months in any 12 month period.
Both countries apply the credit method for the elimination of double taxation.
The treaty will enter into force once the ratification instruments are exchange, and will apply from 1 January of the year following its entry into force.
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