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Ireland-Thailand

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Ireland Approves Tax Treaty with Thailand

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.

Taxes Covered

The treaty covers Irish income tax, corporation tax and capital gains tax, and Thai income tax and petroleum income tax.

Service PE

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.

Withholding Tax Rates

  • Dividends - 10%
  • Interest - 10% if the beneficial owner is a financial institution (including insurance companies) or in connection to a sale on credit by a resident for any equipment, merchandise or services as long as dealing at arm's length; otherwise 15%
  • Royalties -
    • 5% for the use of or the right to use any copyright of literary, artistic or scientific work, including software, and motion pictures and works on film, tape or other means of reproduction for use in connection with radio or television broadcasting
    • 10% for the use of or the right to use industrial, commercial or scientific equipment or any patent
    • 15% for the use of or the right to use any trademark, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience
  • Capital Gains - Generally exempt, although a Contracting state may apply domestic rates in the case of gains from the alienation of immovable property located in the State, movable property forming part of the business property of a permanent establishment in the State, and shares deriving more than 50% of their value directly or indirectly from immovable property in the State unless quoted on a recognized stock exchange

Double Taxation Relief

Both countries apply the credit method for the elimination of double taxation.

Entry into Force and Effect

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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