ARTICLE 21
OFFSHORE ACTIVITIES 1. The provisions of this Article shall apply notwithstanding any other provision of this Convention.
2. A person who is a resident of a Contracting State and carries on activities offshore in the other Contracting State in connection with the exploration or exploitation of the seabed and subsoil and their natural resources situated in that other State shall, subject to paragraphs 3 and 4 of this Article, be deemed in relation to those activities to be carrying on business in that other State through a permanent establishment or fixed base situated therein, and be taxed according to Article 7 or Article 14 as the case may be.
3. The provisions of paragraph 2 and sub-paragraph (b) of paragraph 6 shall not apply where the activities are carried on for a period not exceeding 30 days in the aggregate in any twelve-month period. However, for the purposes of this paragraph:
(a) activities carried on by an enterprise associated with
another enterprise shall be regarded as carried on by
the enterprise with which it is associated if the activities
in question are substantially the same as those carried
on by the last-mentioned enterprise;
(b) two enterprises shall be deemed to be associated if one
is controlled directly or indirectly by the other, or both are
controlled directly or indirectly by a third person or persons.
4. Profits derived by an enterprise of a Contracting State from the transportation of supplies or personnel to a location, or between locations, where activities in connection with the exploration or exploitation of the seabed and subsoil and their natural resources are being carried on in a Contracting State, or from the operation of tugboats and other vessels auxiliary to such activities, shall, subject to Article 8, be taxable only in the Contracting State of which the enterprise is a resident. Except where such vessel or aircraft is operated in international traffic, the provisions of this paragraph shall not apply if the vessel or aircraft is operated by a permanent establishment in the sense of Article 5. In this case the provisions of Article 7 shall apply.
5. (a) Subject to sub-paragraph (b) of this paragraph, salaries, wages and similar remuneration derived by a resident of a Contracting State in respect of an employment connected with the exploration or exploitation of the seabed and subsoil and their natural resources situated in the other Contracting State may, to the extent that the duties are performed offshore in that other State, be taxed in that other State. However, such remuneration shall be taxable only in the first-mentioned State if the employment is carried on offshore for an employer who is not a resident of the other State and provided that the employment is carried on for a period or periods not exceeding in the aggregate 30 days in any twelve-month period.
(b) Salaries, wages and similar remuneration derived by a resident of a Contracting State in respect of an employment exercised aboard a ship or aircraft engaged in the transportation of supplies or personnel to a location, or between locations, where activities connected with the exploration or exploitation of the seabed and subsoil and their natural resources are being carried on in the other Contracting State, or in respect of an employment exercised aboard tugboats or other vessels operated auxiliary to such activities, shall be taxable according to Article 15.
6. Gains derived by a resident of a Contracting State from the alienation of:
(a) exploration or exploitation rights; or
(b) property situated in the other Contracting State and
used in connection with the exploration or exploitation
of the seabed and subsoil and their natural resources
situated in that other State; or
(c) shares deriving their value or the greater part of their
value directly or indirectly from such rights or such
property or from such rights and such property taken
together, may be taxed in that other State.
In this paragraph "exploration or exploitation rights" means rights to assets to be produced by the exploration or exploitation of the seabed and subsoil and their natural resources in the other Contracting State, including rights to interests in or to the benefit of such assets. ARTICLE 22
OTHER INCOME 1. Items of income of a resident of a Contracting State, wherever arising, not dealt with in the foregoing Articles of this Convention shall be taxable only in that State. 2. The provisions of paragraph 1 shall not apply to income, other than income from immovable property as defined in paragraph 2 of Article 6, if the recipient of such income, being a resident of a Contracting State, carries on business in the other Contracting State through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the income is paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 3. Notwithstanding the provisions of paragraphs 1 and 2, items of income of a resident of a Contracting State not dealt with in the foregoing Articles of this Convention and arising in the other Contracting State may also be taxed in that other State. CHAPTER IV
METHOD FOR ELIMINATION OF DOUBLE TAXATION ARTICLE 23
ELIMINATION OF DOUBLE TAXATION 1. When income or profits are subject to tax in both Contracting States, relief from double taxation shall be given in accordance with the following paragraphs of this Article. 2. In Thailand, tax payable in Norway in respect of income or profits derived in Norway shall be allowed as a credit against any tax payable in Thailand in respect of that income or profits. The credit shall not, however, exceed that part of the tax payable in Thailand as computed before the credit is given, which is appropriate to such item of income or profits. 3. In Norway, double taxation shall be eliminated as follows:
(a) Subject to the provisions of the laws of Norway regarding
the allowance as a credit against Norwegian tax of tax
payable in a territory outside Norway (which shall not
affect the general principle hereof), where a resident
of Norway derives income which, in accordance with
the provisions of this Convention, may be taxed in Thailand,
Norway shall allow as a deduction from the tax on the
income of that resident, an amount equal to the income
tax paid in Thailand.
Such deduction shall not, however, exceed that part of
the income tax, as computed before the deduction is
given, which is attributable to the income which may
be taxed in Thailand;
(b) Where, in accordance with any provision of the Convention,
income derived by a resident of Norway is exempt from tax
in Norway, Norway may nevertheless include such income
in the tax base, but shall allow as a deduction from the
Norwegian tax on income that part of the income tax which
is attributable to the income derived from Thailand.
(c) Where, on application by the Competent Authority of
Thailand to the Competent Authority of Norway, designates
a specific investment in Thailand to be an approved
economic development project, the Thai tax mentioned in
sub-paragraph 3 (a) of this Article shall upon approval
by the Norwegian Competent Authority be deemed to
include the amount of tax which under the law of Thailand
and in accordance with this Convention would have been
payable as tax on income but for the tax incentives granted
under the law of Thailand designed to promote economic
development.
(d) Sub-paragraph 3 (c) shall apply only in relation to income
derived in any of the first 10 income years in relation to which
this Convention has effect by virtue of sub-paragraph (b)
of Article 28 and in any later income year that may be agreed
in an exchange of letters for this purpose by the Competent
Authorities of the Government of the Kingdom of Norway and
of the Government of the Kingdom of Thailand.
(e) Where, under any provision of this Convention, income is
relieved from Norwegian tax and, under the law in force in
Thailand, an individual in respect of the said income is
subject to tax by reference to the amount thereof which is
remitted to or received in Thailand and not by reference to
the full amount thereof, then the relief to be allowed under this
Convention in Norway shall apply only to so much of the
income as is taxed in Thailand. CHAPTER V
SPECIAL PROVISIONS ARTICLE 24
NON - DISCRIMINATION 1. Nationals of a Contracting State shall not be subjected in the other Contracting State to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which nationals of that other State in the same circumstances, in particular with respect to residence are or may be subjected. This provision shall, notwithstanding the provisions of Article 1, also apply to persons who are not residents of one or both of the Contracting States. 2. The taxation on a permanent establishment which an enterprise of a Contracting State has in the other Contracting State shall not be less favourably levied in that other State than the taxation levied on enterprises of that other State carrying on the same activities. This provision shall not be construed as obliging a Contracting State to grant to residents of the other Contracting State any personal allowances, reliefs and reductions for taxation purposes on account of civil status or family responsibilities which it grants to its own residents.
3. Except where the provisions of Article 9, paragraph 7 of Article 11 or paragraph 6 of Article 12 apply, interest, royalties and other disbursements paid by an enterprise of a Contracting State to a resident of the other Contracting State shall, for the purpose of determining the taxable profits of such enterprise, be deductible under the same conditions as if they had been paid to a resident of the first-mentioned State.
4. Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned State to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which other similar enterprises of the first-mentioned State are or may be subjected. 5. The provisions of this Article shall only apply to the taxes which are the subject of this Convention.
ARTICLE 25
MUTUAL AGREEMENT PROCEDURE 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Convention, he may, irrespective of the remedies provided by the domestic laws of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 24, to that of the Contracting State of which he is a national. The case must be presented within three years from the receipt of the first notification of the action resulting in taxation not in accordance with the provisions of this Convention. 2. The competent authority shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement, with the competent authority of the other Contracting State with a view to the avoidance of taxation which is not in accordance with the Convention.
3. The competent authorities of the Contracting States shall endeavour to resolve by mutual agreement any difficulties or doubts arising as to the interpretation or application of the Convention. They may also consult together for the elimination of double taxation in cases not provided for in the Convention.
4. The competent authorities of the Contracting States may communicate with each other directly for the purposes of reaching an agreement in the sense of the preceding paragraphs. | 
