ARTICLE 26
Diplomatic Agents and Consular Officers

1.         Nothing in this Convention shall affect the fiscal privileges of diplomatic agents or consular officers  under the general rules of international law or under the provisions of special agreements.

2.         Notwithstanding Article 4, an individual who is a member of a diplomatic mission, consular post or permanent mission of a Contracting State which is situated in the other Contracting State or in a third State shall be deemed for the purposes of the Convention to be a resident of the sending State if he is liable in the sending State to the same obligations in relation to tax on his total income as are residents of that sending State.

3.         The Convention shall not apply to International Organizations, to organs or officials thereof and to persons who are members of a diplomatic mission, consular post or permanent mission of a third State, being present in a Contracting State and who are not liable in either Contracting State to the same obligations in relation to tax on their total income as are residents thereof.

ARTICLE 27
Miscellaneous Rules

1.         The provisions of this Convention shall not be construed to restrict in any manner any exclusion, exemption, deduction, credit, or other allowance now or hereafter accorded

            (a)        by the laws of a Contracting State in the determination of the

                         tax imposed by that State, or

            (b)        by any other agreement entered  into by a Contracting State.

2.         Nothing in the Convention shall be construed as preventing Canada from imposing a tax on amounts included in the income of a resident of Canada according to section 91 of the Canadian Income Tax Act.

3.         The competent authorities of the Contracting State may communicate with each other directly for the purpose of applying the Convention.

CHAPTER VI
FINAL PROVISIONS

ARTICLE 28
Entry into Force

1.         This Convention shall be ratified and the instruments of ratification shall be exchanged as soon as possible.

2.         The Convention shall enter into force upon the exchange of instruments of ratification and its provisions shall have effect:

            (a)        in Canada:

                         (i)         in respect of tax withheld at the source on amounts

                                      paid or credited to non-residents on or after the

                                      first day of January in the calendar year in which the

                                      exchange of instruments of ratification takes place;

                                      and

                        (ii)        in respect of other Canadian tax for taxation years

                                     beginning on or after the first day of January in the

                                     calendar year in which the exchange of instruments of

                                     ratification takes place;

            (b)        in Thailand:

                         (i)         in respect of withholding taxes, on amounts payable

                                      on or after the first day of January in the calendar year

                                      in which the exchange of instruments of ratification

                                      takes place; and

                         (ii)        in respect of other taxes, for tax years or accounting

                                      periods beginning on or after the first day of January

                                      in the calender year in which the exchange of

                                      instruments of ratification takes place.

ARTICLE 29
Termination

          This Convention shall continue in effect indefinitely but either Contracting State may terminate the Convention, through diplomatic channels, by giving to the other Contracting State, written notice of termination on or before June 30 in any calendar year from the fifth year from the year in which the Convention entered into force. In such event, the Convention shall cease to have effect:

            (a)        in Canada:

                         (i)         in respect of tax withheld at the source on amounts

                                      paid or credited to non-residents on or after the first

                                      day of January in the calendar year next following that

                                      in which the notice is given; and

                         (ii)        in respect of other Canadian tax for taxation years

                                      beginning on or after the first day of January in the

                                      calendar year next following that in which the notice is

                                      given;

            (b)        in Thailand:

                         (i)         in respect of withholding taxes, on amounts payable

                                      on or after the first day of January in the calendar year

                                      next following that in which the notice is given; and

                         (ii)        in respect of other taxes, for tax years or accounting

                                      periods beginning on or after the first day of January

                                      in the calendar year next following that in which the

                                      notice is given.

          IN WITNESS WHEREOF, the undersigned duly authorized thereto by their respective Governments, have signed this Convention.

          DONE IN duplicate at Ottawa, this 11th day of April 1984 in the English, French and Thai languages, each version being equally authentic.

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