ARTICLE 21
Professors, Teachers and Researchers 1. An individual who is a resident of a Contracting State immediately before making a visit to the other Contracting State, and who, at the invitation of any university, college, school or other similar educational institution which is recognized by the competent authority in that other Contracting State, visits that other Contracting State for a period not exceeding two years solely for the purpose of teaching or research or both at such educational institution shall be exempt from tax in that other Contracting State on any remuneration for such teaching or research. 2. This Article shall only apply to income from research if such research is undertaken by the individual for the public interest and not primarily for the benefit of some other private person or persons. ARTICLE 22
Other Income Items of income of a resident of a Contracting State not dealt with in the foregoing Articles of this Agreement may be taxed in the State where the income arises. ARTICLE 23
Elimination of Double Taxation 1. The laws in force in either of the Contracting States shall continue to govern the taxation of income in the respective Contracting States except when an express provision to the contrary is made in this Agreement. When income is 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 the case of Lao PDR, double taxation shall be avoided as follows: a) Where a resident of Lao PDR derives income which, in accordance with the provisions of this Agreement, may be taxed in Thailand, Lao PDR shall allow as a deduction from Lao tax on the income of that resident an amount equal to the tax paid in Thailand. Such deduction shall not, however, exceed that part of the Lao tax, as computed before the deduction is given, which is attributable to such items of income. b) Where the income derived from Thailand is a dividend paid by a company which is a resident of Thailand to a company which is a resident of Lao PDR and which owns not less than 25 percent of the shares of the company paying the dividend, the credit shall take into account the tax paid to Thailand by the company paying the dividend in respect of its income. c) For the purposes of subparagraph (a), the term "tax paid in Thailand" shall be deemed to include the amount of Thai tax which would have been paid if the Thai tax had not been exempted or reduced under any special incentive law designed to promote economic development in Thailand, effective on the date of the signature of this Agreement or which may be introduced hereafter in modification of, or in addition to, the existing law. 3. In the case of Thailand double taxation shall be avoided as follows: a) Where a resident of Thailand derives income which, in accordance with the provisions of this Agreement, may be taxed in Lao PDR, Thailand shall allow as a deduction from Thai tax on the income of that resident an amount equal to the tax paid in Lao PDR. Such deduction shall not, however, exceed that part of the Thai tax, as computed before the deduction is given, which is attributable to such items of income. b) Where the income derived from Lao PDR is a dividend paid by a company which is a resident of Lao PDR to a company which is a resident of Thailand and which owns not less than 25 percent of the shares of the company paying the dividend, the credit shall take into account the tax paid to Lao PDR by the company paying the dividend in respect of its income. c) For the purposes of subparagraph (a), the term "tax paid in Lao PDR" shall be deemed to include the amount of Lao tax which would have been paid if the Lao tax had not been exempted or reduced under any special incentive law designed to promote economic development in the Lao PDR, effective on the date of signature of this Agreement or which may be introduced hereafter in modification of, or in addition to, the existing law. 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 are or may be subjected. 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. 3. Enterprises or a Contracting State, that 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. 4. The provisions of this Article 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. 5. The provisions of this Article shall only apply to the taxes which are the subject of this Agreement ARTICLE 25
Mutual Agreement Procedure 1. Where a resident of a Contracting State considers that the actions of one or both of the Contracting State result or will result for him in taxation not in accordance with the provision of this Agreement, he may, irrespective of the remedies provided by the domestic laws of those State, present his case to the competent authority of the Contracting State of which he is a resident. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of this Agreement. 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 Agreement. 3. The competent authorities of the Contracting States shall endevour to resolve by mutual agreement any difficulties or doubts arising as to the interpretation or application of the Agreement. 4. The competent authorities of the Contracting State may communicate with each other directly for the purposes of reaching an agreement in the sense of the preceding paragraphs. | 
