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Germany – Thailand · Source editionArticle 10

Unreviewed · applicability unverified

(1)

(1) Dixidends paid by a company which is a resident of a Contracting State to a resident of the other Con- tracting State may be taxed in that other State

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(2)

(2) However, such dividends may be taxed in the Contrecung State of which the company paying the dividends 1s a resident, but a) the Thai tax shall not exceed 1. 20 per cent of the gross amount of the dividends if the company paying the dividends engages in an industrial undertaking or if the recipient of the dividends is @ company which is a resident of the Federal Republic owning at least 25 per cent of the voting shares of the company paying the dividends, 2.15 per cent of the gross amount of the dividends if the company paying the dividends engages in an industrial undertaking and the recipient of the dividends is a company which is a resident of the Federal Republic owning at least 25 per cent of the voting shares of the former company: b) the German tax shall not exceed: 1, 20 per cent of the gross amount of the dividend, unless sub-paragraph 2 applies; 2. 15 per cent of the gross amount of the dividends, Hf the recipient of the dividends is a company which is a resident of Thailand owning at least 25 per cent of the voting shares of the company paying the dividends.

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(3)

(3) Notwithstanding the provisions of paragraph 2 the tax of a Contracting State on dividends paid by a company which is a resident of that State may exceed the rates provided for in that paragraph, but shall not exceed 25 per cent of the gross amount of the dividends, if @) the corporation tax of that State on distributed profits is lower than that on undistributed profits and the difference between those two rates is 20 percentage points or more, and b) such dividends are paid by a company which is a resident of that State to a company resident of the other State and which owns at least 25 per cent of the voting shares of the first-mentioned company.

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(4)

(4) In this Article a) the term "dividends“ means income from shares and income from other corporate rights assimilated to income from shares by the taxation law of the State of which the company making the distribution is a resident; b) the term “industrial undertaking" means 1. any undertaking engaged in i) manufacturing, assembling and processing, i) construction, civil engineering and ship- building, iii) production of electricity, hydraulic power, gas or the supply of water, or iv) agriculture, forestry and fishery and the carrying on of a plantation, nd 2. any other undertaking entitled to the privileges accorded under the laws of Thailand on the promo ion of industrial investment, and 3. any other undertaking which may be declared 10 be an “industrial undertaking” for the purpose of this Article by the competent authority ol Thailand

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(5)

(5) The provisions of paragraphs 1 to 3 shall not apply if the recipient of the dividends, being a resident of a Contracting State, has in the other Contracting State, of which the company paying the dividends is a resident, a permanent establishment with which the holding by virtue of which the dividends are paid is effectively connected, provided that under the law of that other State the dividends are taxed as part of the profits of the permanent establishment.

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(6)

(6) Where a company which is a resident of a Con- tracting State derives profits or income from the other Contracting State, that other State may not impose any tax on the dividends paid by the company to persons who are not resident of that other State, or subject the company's undistributed profits to a tax on undistributed profits even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other State

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Source, edition and limits
Source edition
de-thailand-1968-base | BGBl. 1968 II S. 589 | signed 1967-07-10 | published 1968-07-26 | Signed: 1967-07-10 | Gazette publication: 1968-07-26
Source form
retained original official-publication scan; reader uses a separately retained unreviewed OCR derivative
Source scope
original implementing law, DE/EN/Thai base treaty and accompanying exchange of notes; not a current consolidated text
Retrieved
2026-09-30
Text and language scope
ORIGINAL EDITION, unreviewed OCR. Authentic treaty languages: German (de), English (en), Thai (th). Distinct DE/EN assets use separate left/right physical columns on even PDF pages2–32. Thai original text IS PRESENT on alternating odd PDF pages3–33, but retained OCR is unusable for Thai: no Thai machine reader is supplied. Missing usable authentic-language asset: th; no full-language claim. German exchange-of-notes text is labelled Übersetzung in the original. All OCR defects, damaged numerals, uncertain punctuation and line-end hyphens are retained. Source-observed article/paragraph IDs do not replace the visibly erroneous OCR wording. Unreviewed coordinate-based machine transcription of this original source edition only. OCR words are unchanged; rows reconstructed by word coordinates. Known misspellings and damaged numerals remain visible. Source-observed structural paragraph IDs may differ from erroneous OCR numerals. This is not exact legal transcription. Treaty preamble, closing formula, exchange of notes and signatures are separate retained assets, not part of the last article. Full supplements: /review/de-thailand-1968-base/. PDF page links identify pages, not verified paragraph correspondence.
Review status
Pending human wording, completeness, source-authority, currentness, alignment and rendering review. No legal review performed.
Currentness
Original source edition; not a verified current-law consolidation. Unknown as current law. Signature: 1967-07-10; consent law: 1968-07-19; gazette publication: 1968-07-26. Edition ID year is the retained publication label, NOT the signature year. Treaty entry into force (retained audit/cached article): 1968-12-04. Roster general application: 1967-01-01; NOT a universal tax-specific rule and NOT the entry date. Cached article entry statements (possibly about multiple instruments): ['4. Dezember 1968']. None means unresolved, not no legal effect. All dates retain their evidence scope; no fresh current-law verification. Bounded agent triage, no qualified wording/alignment/legal review. No exhaustive verification of all later 2026 developments. Matching digest proves retained source identity, not legal force.
Protocols and later instruments
The printed accompanying exchange of notes is retained separately from treaty articles; German note text is marked Übersetzung in the Thailand original. Retained edition-audit relationships: []. MLI effects, later protocols, replacements, suspensions, complete amendment chain and current applicability have NOT been verified or incorporated. No current-law claim. Source-triage warnings: Bounded agent triage, no qualified wording/alignment/legal review. No exhaustive verification of all later 2026 developments. Matching digest proves retained source identity, not legal force.
Text language and status
en · authentic-language-transcription · machine-transcription
Citation
BGBl. 1968 II S. 589
SHA-256
8a0e863c203f731b138220878bf7b1edec742b93bafba075bfb4ab7146b8c627

Citation

Copyable citation

BGBl. 1968 II S. 589 | de-thailand-1968-base | de-thailand-1968-base | BGBl. 1968 II S. 589 | signed 1967-07-10 | published 1968-07-26 | Signed: 1967-07-10 | Gazette publication: 1968-07-26 | Article 10 | en | Pending human wording, completeness, source-authority, currentness, alignment and rendering review. No legal review performed. | /library/treaties/de-thailand-1968-base/en/articles/article-10/

Disclaimers

Language switching retains matching article and paragraph identifiers. The mapping does not confirm reviewed legal or translational equivalence.

BGBl. 1968 II S. 589

Unreviewed machine transcription. Not a verified current-law consolidation or legal advice. Later changes may be missing.

Source details · Preamble and protocol

Source-page links are references, not human paragraph verification.

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