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Application of the MLI to the Tax Treaty between Japan and Thailand

   The MLI enters into force for Japan on January 1, 2019, and for Thailand on July 1, 2022.
 Based on the reservations and notifications submitted by Japan on September 26, 2018 and April 21, 2022 and by Thailand on March 31, 2022, the MLI applies to the tax treaty between Japan and Thailand as described below.

1. Tax treaty covered by the MLI
- “Convention between Japan and Thailand for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income”
       Date of signature: April 7, 1990
       Date of entry into force: August 31, 1990

2. Provisions of the MLI applicable to the tax treaty
    - Article 6(1) (Preamble language describing the intent of the Contracting Jurisdictions that the tax treaty will not create opportunities for non-taxation or reduced taxation)
    - Article 7(1) (Provisions that deny the benefits under the tax treaty where the principal purpose or one of the principal purposes of any arrangement or transaction was to obtain those benefits)
    - Article 12(1) and (2) (Provisions regarding an agent that is deemed to constitute a permeant establishment)
    - Article 13(2) (Provisions regarding an activity that is deemed not to constitute a permanent establishment even if the activity is carried on through a fixed place of business)
    - Article 13(4) (Provisions for combining business activities carried on by closely related persons for the purpose of determining whether a permanent establishment exists)
    - Article 15 (Provisions for the definition of a person closely related to an enterprise)
    - Article 16(2), 2nd sentence (Provisions that provide that any agreement reached under a mutual agreement procedure shall be implemented)

3. Entry into effect
    The provisions of the MLI shall have effect in each Contracting Jurisdiction with respect to the tax treaty between Japan and Thailand:
(a) with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after January 1, 2023; and
(b) with respect to all other taxes levied by that Contracting Jurisdiction, for taxes levied with respect to taxable periods beginning on or after January 1, 2023.