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Ireland; Thailand

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Treaty between Ireland and Thailand – details

Details of the Ireland - Thailand Income Tax Treaty (2013), signed on 4 November 2013, have become available. The treaty was concluded in the English language. The treaty generally follows the OECD Model (2010).

The maximum rates of withholding tax are:
- 10% on dividends (article 10 of the treaty);
- 15 % on interest in general (article 11(2)(c) of the treaty), and 10% if the interest is beneficially owned by any financial institution (article 11(2)(a) of the treaty) or owned by a resident of the other contracting state and is paid in respect to a sale on credit of any equipment, merchandise or service (article 11(2)(b) of the treaty); and
- 5% on copyright royalties (article 12(2)(a) of the treaty), 10% on royalties paid for the use of equipment (article 12(2)(b) of the treaty), and 15% on royalties paid for trademarks, designs and know-how (article 12(2)(c) of the treaty).
Deviations from the OECD Model include that:
- a building site, a construction, installation or assembly project, or supervisory activities in connection therewith constitute a permanent establishment if they last for more than 6 months (article 5 (3)(a) of the treaty);
- the furnishing of services, including consultancy services, by an enterprise through employees or other personnel constitutes a permanent establishment if the activities of that nature continue (for the same or connected projects) within a contracting state for a period or periods exceeding 6 months within any 12-month period (article 5(3)(b) of the treaty);
- activities connected with exploration or exploitation of the sea bed and sub-soil constitute a permanent establishment if they continue for more than 3 months within any 12-month period (article 5(4) of the treaty);
- the treaty contains a pre-2010 version of article 7 of the OECD Model;
- capital gains generally may be taxed in the alienator's residence state; however, gains from the alienation of any property other than referred to in article 13(1)-(4) and derived from the other contracting state may be taxable in the other contracting state if the alienator was a resident in that state any time within a 3-year period immediately preceding the alienation; and
- the treaty does not include a provision on assistance in the collection of taxes.
Both states generally provide for the credit method to avoid double taxation (article 23 of the treaty).

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