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Double Taxation Avoidance Agreement Between Thailand and Sri Lanka

The Government of the Kingdom of Thailand and the Government of the    Democratic Socialist Republic of Sri Lank, desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, have agreed as follows:
 Personal Scope
This Convention shall apply to persons who are residents of one or both of the Contracting States.
Taxes Covered
This Convention shall apply to taxes on income imposed on behalf of each Contracting State, or of its local authorities irrespective of the manner in which they are levied.
There shall be regarded as taxes on income all taxes imposed on total income, or on elements of income, including taxes on gains from the alienation of movable or immovable property, as well as taxes on capital appreciation.
The existing taxes to which this Convention shall apply are:
In Sri Lanka
  • The income tax, including the income tax based on the turnover of enterprises licensed by the Greater  Colombo Economic Commission (hereinafter referred to as “Sri Lanka tax”);
In Thailand 
  • The income tax and
  • The petroleum income tax (hereinafter referred to as “Thai tax”).
 Permanent Establishment
  • For the purposes of this Convention, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on.
The term "permanent establishment" shall include especially:
  • A place of management:
  • A branch
  • An office
  • A factory
  • A workshop and
  • A mine, an oil or gas well, a quarry or other place of extraction of natural resources. 
The term "permanent establishment" likewise encompasses:
  • A building site, a construction, assembly or installation project, but only where such site, project or activities continue for a period of more than 183 days.

The furnishing of services, including consultancy services, by an enterprise through employees or other personnel engage by the enterprise for such purpose, but only where activities of that nature continue (for the same or a connected project) within the country for a period or periods aggregate more than 183 days within any 12 month period.

Last Updated on: 19-05-2010

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