(1) The profits of an enterprise of a Contracting State
shall be taxable only in that State unless the enterprise
carries on business in the other Contracting State through
& permanent establishment situated therein If the enter-
prise carries on business as aforesaid, the profits of the
enterprise may be taxed in that other State but only so
much of them as is attributable to that permanent estab:
lishment.
(2) Where an enterprise of a Contracting State carries
on business in the other Contracting State through a
permanent establishment situated therein, there shall in
each Contracting State be attributed to that permanent
establishment the profits which it might be expected to
make if it were a distinct and separate enterprise
engaged in the same or similar activities under the same
or similar conditions and dealing wholly independently
with the enterprise of which it is a permanent estab.
lishment.
(&) In the determination of the profits of a permanent
establishment, there shall be allowed as deductions ex-
penses which are incurred for the purposes of the
permanent establishment including executive and general
administrative expenses so incurred, whether in the
State in which the permanent establishment is situated
or elsewhere.
(4) No profits shall be attributed to a permanent estab
lishment by reason of the mere purchase by that per-
manent establishment of goods or merchandise for the
enterprise.
(5) Where profits include items of income which are
dealt with separately in other Articles of this Agreement
then the provisions of those Articles shall not be affected
by the provisions of this Article,
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 7 | 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-7/
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