ARTICLE 21
STUDENTS AND TRAINEES 1. An individual who was a resident of a Contracting State immediately before visiting the other Contracting State and is temporarily present in that Contracting State solely as a student at a university, college or other similar educational institution or as a business apprentice shall, from the date of his first arrival in that Contracting State in connection with that visit be exempt from tax in that Contracting State: (a) on all remittance from abroad for purposes of his maintenance, education or training, and (b) for a period not exceeding in the aggregate five years, on any remuneration for personal services rendered in that Contracting State with a view to supplementing the resources available to him for such purposes. 2. An individual who was a resident of a Contracting State immediately before visiting the other Contracting State and is temporarily present in that Contracting State solely for the purpose of study, research or training as a recipient of a grant, allowance or award from a scientific, educational, religious or charitable organization or under a technical assistance program entered into by the Government of a Contracting State shall for a period not exceeding five years from the date of his first arrival in that Contracting State in connection with that visit be exempt from tax in that Contracting State on (a) the amount of such grant, allowance or a ward; (b) all remittances from abroad for the purposes of his maintenance, education or training; and (c) any remuneration for personal services in that other Contracting State provided that such services are in connection with his study, research, training or incidental thereto. 3. An individual who was a resident of a Contracting State immediately before visiting the other Contracting State and is temporarily present in that Contracting State solely as a trainee for the purpose of acquiring technical, professional or business experience, shall for a period not exceeding two years from the date of his first arrival in that Contracting State in connection with that visit be exempt from tax in that Contracting State on : (a) all remittance from abroad for purposes of his maintenance, education or training; and (b) any remuneration, for personal services rendered in that Contracting State, provided such services are in connection with his studies or training or incidental thereto. ARTICLE 22
INCOME NOT EXPRESSLY MENTIONED Items of income of a resident of a Contracting State which are not expressly mentioned in the foregoing Articles of this Convention shall be taxable only in that Contracting State except that, if such income is derived from sources within the other Contracting State, it may also be taxed in accordance with the law of that other State. ARTICLE 23
ELIMINATION OF DOUBLE TAXATION 1. In the case of Thailand : (a) Philippine tax payable in respect of income derived from the Philippines shall be allowed as a credit against Thai tax payable in respect of that income; (b) Where such income is a dividend paid by a company which is a resident of the Philippines to a company which is a resident of Thailand and which owns not less than 15 per cent of votingshares of the company paying the dividend, the credit shall take into account the Philippine tax payable by that company in respect of its income, and (c) The credit shall not, however, exceed that part of the Thai tax, as computed before the credit is given, which is appropriate to such item of income. 2. The term "Philippine tax payable" shall be deemed to include the amount of Philippine tax which would have been paid if the Philippine tax had not been exempted or reduced in accordance with this Convention and/or the special incentive laws designed to promote economic development in the Philippines, effective on the date of signature of this Convention, or which may be introduced in the future in the Philippine taxation laws in modification of, or in addition to, the existing laws. 3. In the case of the Philippines : Subject to the laws of the Philippines regarding the allowance as a credit against Philippine tax of tax payable in any country other than the Philippines, (a) Thai tax payable in respect of income derived from Thailand shall be allowed as credit against the Philippine tax payable in respect of that income; (b) Where such income is a dividend paid by a company which is a resident of Thailand to a company which is a resident of the Philippines and which owns not less that 15 per cent of voting shares of the company paying the dividend, the credit shall take into account the Thai tax payable by that company in respect of its income; and (c) The credit shall not, however, exceed that part of the Philippine tax as computed before the credit is given, which is appropriate to such item of income. 4. The term "Thai tax payable" shall be deemed to include the amount of Thai tax which would have been paid if the Thai tax had not been reduced in accordance with this Convention and/or the special incentive laws designed to promote economic development in Thailand, effective on the date of signature of this Convention, or which may be introduced in the future in the Thai taxation laws in modification of, or in addition to, the existing laws. ARTICLE 24
NON-DISCRIMINATION 1. Nationals of a Contracting State shall not be subject 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. Nothing in this Article shall 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. 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. Notwithstanding the preceding provision of this Article, either Contracting State may, in the promotion of necessary industry or business, limit to its nationals the enjoyment of tax incentives granted by it. 6. In this Article, the term "taxation" means taxes, which are the subject of this Convention. ARTICLE 25
MUTUAL AGREEMENT PROCEDURE 1. Where a resident of a Contracting State considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with this Convention, he may, without prejudice to the remedies provided by the national laws of these States, address 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 Contracting State of which he is a national, an application in writing stating the grounds for claiming the provision of such taxation. To be admissible, the said application must be submitted within two years from the first notification of the action which gives rise to taxation not in accordance with the 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 an appropriate 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 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 interpretations or application of the Convention. They may also consult together for the elimination of double taxation in cases not provided for in this Convention. 4. The competent authorities of the Contracting States may communicate with each other directly for the purpose of reaching an agreement in the sense of the preceding paragraphs. | 
