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
Income Not Expressly Mentioned 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 paragraph 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 the other State. ARTICLE 23
Limitation of Benefits The competent authorities of the Contracting States, upon their mutual agreement, may deny the benefits of this Convention to any person, or with respect to any transaction, if in their opinion the receipt of those benefits, under the circumstances, would constitute an abuse of the Convention according to its purposes. ARTICLE 24
Elimination of Double Taxation 1. Subject to the laws of Thailand regarding the allowance as a credit against Thai tax of tax paid in any country other than Thailand (and to any modification thereof which does not affect the general principal hereof), Israelitax paid in respect of income derived from Israel shall be allowed as a credit against Thai tax paid in respect of that income. The amount of credit shall not, however, exceed that portion of Thai tax which is appropriate to that income. 2. Subject to the laws of Israel regarding the allowance as a credit against Israeli tax of tax paid in any country other than Israel (and to any modification thereof which does not affect the general principal hereof), Thai tax paid in respect of income derived from Thailand shall be allowed as a credit against Israeli tax paid in respect of that income. The amount of credit shall not, however, exceed that portion of Israeli tax which is appropriate to that income. 3. For the purposes of paragraph 1 of this Article, with respect to income or profits as to which any of the following provisions are applicable, the term "Israeli tax paid" shall include the difference, if any, between the tax payable in accordance with such following provisions and the tax payable, without reference to this Convention, in accordance with general Israeli tax law, in respect of such income or profits: (a) the Encouragement of Capital Investments Law - 1959, the Law for the Encouragement of Investments (Capital Intensive Companies) - 1990 and the Free Trade Areas Law - 1994, so far as they were in force on, and have not been modified since, the date of signature of this Convention, or have been modified only in minor respects so as not to affect their general character; or (b) any other provision which may subsequently be made granting an exemption or reduction of tax which is agreed by the competent authorities of the Contracting States to be of a substantially similar character, if it has not been modified thereafter or has been modified only in minor respects so as not to affect its general character. 4. For the purposes of paragraph 2 of this Article, the term "Thai tax paid" shall be deemed to include any amount which would have been payable as Thai tax for any year but for an exemption or reduction of tax granted with a view to promoting industrial, commercial, scientific, educational or other development in Thailand, for that year or any part thereof under: (a) the Investment Promotion Act BE 2520 so far as it was in force on, and has not been modified since, the date of signature of this Convention, or has been modified only in minor respects so as not to affect its general character; or (b) any other provision which may subsequently be made granting an exemption or reduction of tax which is agreed by the competent authorities of the Contracting States to be of a substantially similar character, if it has not been modified thereafter or has been modified only in minor respects so as not to affect its general character. ARTICLE 25
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. 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 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. 6. In this Article the term "taxation" means taxes which are the subject of this Convention. | 
