(1) The laws in force in either of the Contracting
States will continue to govern the assessment and
taxation of income and capital in the respective Con-
tracting State except where express provision to the
contrary is made in this Agreement.
(2) Subject to the provisions of paragraph 1, tax shall
be determined in the case of a resident of the Federal
Republic as follows:
a) Unless the provisions of subparagraph b) below apply,
there shall be excluded from the basis upon which
German tax is imposed any item of income from
sources within Thailand and any item of capital
situated within Thailand which according to this
Agreement may be taxed in Thailand. The Federal
Republic, however, retains the right to take into
account in the determination of its rate of tax the
items of income and capital so excluded. The first
sentence shall in the case of dividends apply only
to such dividends as are paid to a company limited
by shares (Kapitalgesellschaft) which is a resident
of the Federal Republic by a company which is a
resident of Thailand and at least 25 per cent of the
voting shares of which are owned by the first-
mentioned company. There shall also be excluded
from the basis upon which German tax is imposed
any share-holding, the dividends on which, if paid,
would be excluded from the tax basis according to
the immediately foregoing sentence.
b) Tax payable under the laws of Thailand and in ac-
cordance with this Agreement on the following items
of income from sources within Thailand shall, subject,
to the provisions of German tax law regarding credit
for foreign tax, be allowed as a credit against such
German tax on income as is payable in respect of the
following items of income:
1. profits derived by operating ships in international
traffic which may be taxed in Thailand according to
paragraph 2 of Article 8;
2. dividends not dealt with in subparagraph a) above;
3. interest;
4, royalties and such gains as are mentioned in para-
graph 3 of Article 12;
5, profits which may be taxed in Thailand according
to paragraph 2 of Article 15;
6. remuneration mentioned in paragraph 1 of Ar-
ticle 17 paid to a German national who is not also
a Thai national;
7. pensions and other payments and annuities which
may be taxed in Thailand according to paragraph 1
of Article 18.
(3) Subject to the provisions of paragraph 1, tax shall
be determined in the case of a resident of Thailand as
follows:
a) Unless the provisions of subparagraph b) below apply.
there shall be excluded from the basis upon which
Thai tax is imposed any item of income from sources
within the Federal Republic and any item of capital
situated within the Federal Republic which according
to this Agreement may be taxed in the Federal Re-
public. Thailand, however, retains the right to take
into account in the determination of its rate of tax
the items of income and capital so excluded. The
first sentence shall in the case of dividends apply
only to such dividends as are paid to a company
which is a resident of Thailand by a company himited
by shares (Kapitalgesellschaft) which is a resident of
the Federal Republic and at least 25 per cent of the
voting shares of which are owned by the first-
mentioned company. There shall also be excluded
from the basis upon which Thai tax is imposed any
shareholding, the dividends on which, if paid, would
be excluded from the tax basis according to the
immediately foregoing sentence.
b) Tax payable under the laws of the Federal Republic
and in accordance with this Agreement by a resident
of Thailand on income from sources within the
Federal Republic shall be allowed as credit against
‘Thai tax if such income consists of:
1. profits derived by operating ships in international
traffic which may be taxed in the Federal Republic
according to paragraph 2 of Article 8;
2. dividends not dealt with in subparagraph a) above;
3. interest;
4. royalties and gains such as are mentioned in para-
graph 3 of Article 12;
5. profits which may be taxed in the Federal Republic
according to paragraph 2 of Article 15;
6 remuneration mentioned in paragraph 1 of Ar-
ticle 17 paid to a Thai national who is not also a
German national;
7. pensions and other payments and annuities which
may be taxed in the Federal Republic according to
Paragraph 1 of Article 18.
Such credit shall be based on the amount of tax paid to
the Federal Republic but shall not exceed the portion of
the Thai tax which net income from sources within the
Federal Republic bears to the entire net income subject
to Thai tax. In determining such entire net income a loss
incurred in any country shall not be taken into account.
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
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 22 | 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-22/
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