ARTICLE 26 EXCHANGE OF INFORMATION
1. The competent authorities of the Contracting States shall exchange such information as is necessary for carrying out the provisions of this Convention or of the domestic laws of the Contracting States concerning taxes covered by the Convention insofar as the taxation thereunder is not contrary to the Convention. Any information so received by a Contracting State shall be treated as secret in the same manner as information obtained under the domestic laws of that State, and shall be disclosed only to persons or authorities (including courts and administrative bodies) involved in the assessment or collection of, the enforcement or prosecution in respect of, or the determination of appeals in relation to, the taxes covered by the Convention. Such persons or authorities shall use the information only for such purposes. They may disclose the information in public court proceedings or in judicial decisions. 2. In no case shall the provisions of paragraph 1 be construed so as to impose on a Contracting State the obligation: a) to carry out administrative measures at variance with the laws and administrative practice of that or of the other Contracting State; b) to supply information which is not obtainable under the laws or in the normal course of the administration of that or of the other Contracting State; c) to supply information which would disclose any trade, business, industrial, commercial or professional secret or trade process, or information, the disclosure of which would be contrary to public policy (ordre public). ARTICLE 27 DIPLOMATIC AND CONSULAR MISSIONS AND THEIR MEMBERS Nothing in this Convention shall affect the fiscal privileges of diplomatic and consular missions and their members under the general rules of international law or under the provisions of special agreements between the two Contracting States. CHAPTER VI FINAL PROVISIONS ARTICLE 28 ENTRY INTO FORCE 1. The Contracting States shall notify each other in writing that their constitutional requirements for entry into force of this Convention have been fulfilled. 2. The Convention shall enter into force on the date of the latter of the notifications referred to in paragraph 1 and its provisions shall apply (i) in respect of taxes withheld at source, to amounts of income, derived on or after the first day of January in the calendar year next following the year in which the Convention enters into force; and (ii) in respect of other taxes on income, to such taxes chargeable for any tax year or accounting period, beginning on or after the first day of January in the calendar year next following the year in which the Convention enters into force. ARTICLE 29 TERMINATION This Convention shall remain in force until terminated by one of the Contracting States. Either Contracting State may terminate the Convention, through diplomatic channels, by giving notice of termination at least six months before the end of any calendar year following after the period of five years from the date on which the Convention enters into force. In such event, the Convention shall cease to have effect: (i) in respect of taxes withheld at source, on amounts of income derived on or after the first day of January in the calendar year next following the year in which the notice is given; and (ii) in respect of other taxes on income, on such taxes chargeable for any tax year or accounting period beginning on or after the first day of January in the calendar year next following the year in which the notice is given. IN WITNESS WHEREOF the undersigned, duly authorized thereto, have signed this Convention. DONE in duplicate at................on................in Bulgarian, Thai and English languages, all texts being equally authentic. In case of divergence in interpretation the English text shall prevail. FOR THE REPUBLIC OF BULGARIA | FOR THE KINGDOM OF THAILAND |
PROTOCOL At the time of signature of the Convention between the Republic of Bulgaria and the Kingdom of Thailand for the avoidance of double taxation with respect to taxes on income, the undersigned have agreed that the following provisions shall form an integral part of the Convention. With reference to paragraph 2 of Article 8, it is understood that in the event that a Contracting State applies a lesser tax rate on income derived by an enterprise of any other Country from the operation of ships in international traffic, such rate shall apply to this Convention. IN WITNESS WHERE OF the undersigned, duly authorized thereto, have signed this Convention. DONE in duplicate at............on.................in Bulgarian, Thai and English languages, all texts being equally authentic. In case of divergence in interpretation the English shall prevail. FOR THE REPUBLIC OF BULGARIA | FOR THE KINGDOM OF THAILAND |
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