Business Tax Act, 2009
Business Tax (Double Taxation Agreement) (No. 4) Regulations, 2004
Statutory Instrument 36 of 2004
- Commenced on 14 April 2006
- [This is the version of this document at 8 November 2017.]
1. CitationThese Regulations may be cited as the Business Tax (Double Taxation Agreement) (No. 4) Regulations, 2004.
2. Declaration and effect of AgreementIt is hereby declared that the Government of the Republic of Seychelles and the Government of the Republic of the Kingdom of Thailand have entered into the Agreement specified in the Schedule for the purposes of avoidance of double taxation and prevention of fiscal evasion and that the Agreement shall have effect in relation to the tax imposed under this Act.
Agreement between the Government of the Republic of Seychelles and the Government of the Kingdom of Thailand for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on incomeThe Government of the Republic of Seychelles and the Government of the Kingdom of Thailand,Desiring to conclude an Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income, and to promote and strengthen the economic relations between the two countries,HAVE AGREED AS FOLLOWS:
Article 1 – Personal scopeThis Agreement shall apply to persons who are residents of one or both of the Contracting States.
Article 2 – Taxes covered
Article 3 – General definitions
Article 4 – Resident
Article 5 – Permanent establishment
Article 6 – Income from immovable property
Article 7 – Business profits
Article 8 – Income or profits from shipping and air transport
Article 9 – Associated enterprises
Article 10 – Dividends
Article 11 – Interest
Article 12 – Royalties
Article 13 – Capital gains
Article 14 – Income from independent personal services
Article 15 – Income from dependent personal services
Article 16 – Director's feesDirectors' fees and other similar payments derived by a resident of a Contracting State in his capacity as, or on behalf of, a member of the board of directors or any other similar organ of a company which is a resident of the other Contracting State may be taxed in that other State.
Article 17 – Income of artistes and sports persons
Article 18 – Pensions
Article 19 – Governmental function
Article 20 – Payments to students and traineesAn individual who is or was immediately before visiting a Contracting State a resident of the other Contracting State and whose visit to the first-mentioned Contracting State is solely for the purpose of—
Article 21 – Payments to professors, teachers and researchers
Article 22 – Other income
Article 23 – Elimination of double taxation
Article 24 – Non-discrimination
Article 25 – Mutual agreement procedure
Article 26 – Exchange of information
Article 27 – Members of diplomatic missions and consular postsNothing in this Agreement shall affect the fiscal privileges of members of diplomatic missions or consular posts under the general rules of international law or under the provisions of special agreements.
Article 28 – Entry into force
Article 29 – TerminationThis Agreement shall remain in force indefinitely, but either of the Contracting States may, on or before 30th June in any calendar year beginning after the expiration of a period of ten (10) years from the date of its entry into force, give to the other Contracting State, through diplomatic channels, written notice of termination.In such event the Agreement shall cease to have effect—
History of this document
08 November 2017 this version
14 April 2006