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HMRC internal manual

Double Taxation Relief Manual

From
HM Revenue & Customs
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DT: Thailand: double taxation agreement, Article 28: Termination

This Convention shall remain in force until terminated by one of the ContractingStates. Either Contracting State may terminate the Convention, through the diplomaticchannel, by giving notice of termination at least six months before the end of anycalendar year beginning on or after the expiration of a period of five years from the dateof its entry into force. In such event, the Convention shall cease to have effect:

(a) in the United Kingdom:

 

 

(i) in respect of income tax and capital gains tax, for any year of assessment beginning on or after 6 April in the calendar year next following that in which the notice is given;
(ii) in respect of corporation tax, for any financial year beginning on or after 1 April in the calendar year next following that in which the notice is given;
(iii) in respect of petroleum revenue tax, for any chargeable period beginning on or after 1 January in the year next following that in which the notice is given; and
(iv) in respect of development land tax, for any realised development value accruing on or after 1 April in the year next following that in which the notice is given;

 

(b) in Thailand:
in respect of Thai tax, for taxable years and accounting periods beginning after the end of the calendar year in which the notice is given.