Ireland – Thailand Tax Treaty Enters Into Force
The Income and Capital Tax Treaty between Ireland and Thailand entered into force on 11 March 2015 and will enter into effect on 1 January 2016.
The Treaty was signed on 4 November 2013.
In accordance with the treaty, the following withholding taxes will apply:
Dividends: 10%.
Interest:
• 0% if the interest is paid to the Government of the other Contracting State.
• 10% if the beneficial owner of the interest is any financial institution (including an insurance company).
• 10% if the interest is paid with respect to the indebtedness arising as a consequence of a sale on credit, merchandise or services, except where the sale was between persons not dealing with each other at arm’s length.
• 15% in all other cases.
Royalties:
• 5% on royalties for the use of or the right to use any copyright of literary, artistic or scientific work, including software, and motion pictures and works on film, tape or other means of reproduction for use in connection with radio or television broadcasting.
• 10% on royalties for the use of or the right to use industrial, commercial or scientific equipment or any patent.
• 15% on royalties for the use of or the right to use any copyright of literary, artistic or scientific work, including software, and motion pictures and works on film, tape or other means of reproduction for use in connection with radio or television broadcasting.