This agreement does not affect the tax privileges of diplomatic or consular officials, in accordance with the general rules of international law or the provisions of specific agreements. 2. The competent authority endeavours to resolve the matter by mutual agreement with the competent authority of the other State party with respect to tax evasion which is not in accordance with this agreement, where the objection is well founded and does not itself reach an appropriate solution. (iv) any institute 100% owned by the Government of Myanmar, as can be agreed from time to time between the competent authorities of the State Party. 1. Where a resident of a contracting state believes that the actions of one or both of the contracting states result in or lead to an imposition that is not in accordance with this agreement, he may, notwithstanding the remedies provided by the tax laws of those states, the competent authority of the state, its resident or, if its case falls under Article 25, paragraph 1 , to the state of which he is a national. The case must not be brought in accordance with the provisions of the agreement within three years of the first notification of the measure leading to taxation. Five of them. The term "interest" used in this article refers to income from any receivables, whether or not they are guaranteed by mortgages, and whether or not they have the right to participate in the debtor`s profits, including income from government bonds or bonds, including premiums and prices related to those securities, bonds or bonds, as well as income that is equated with income from state tax legislation related to the contract. Revenues are generated. The Government of the Republic of the Union of Myanmar and the Government of the Kingdom of Thailand have reached an agreement to avoid double taxation and prevent tax evasion with respect to income tax, as follows: (e) Where the status of the resident cannot be determined in accordance with paragraphs (a) d), the competent authorities of the contracting states resolve the matter by mutual agreement. 2. The imposition of a stable establishment that a firm of one contracting state has in the other contracting state is not perceived less favourably in that other state than the taxation applied to the enterprises of that other state carrying out the same activities.
1. Legislation in one of the contracting states continues to govern the taxation of income in the relevant contracting state, unless this agreement expressly provides otherwise. Where income is taxable in the two contracting states, double taxation is granted in accordance with the following paragraphs of this article. 3. The existing taxes to which the agreement applies are: 3. The term "dividends" used in this article refers to income from shares or other rights that are not debts, that are involved in profits, as well as income from other corporate rights which, according to the laws of the state in which the company distributing the distribution is subject to the same tax treatment as the income of the shares.