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Double Taxation Agreement
"Need to draft a Double Taxation Agreement between Singapore and Thailand, focusing particularly on technology sector income and digital services, with specific provisions for cryptocurrency trading to be implemented by March 2025."
1. Parties: Identification of the contracting states
2. Background: Intent to prevent double taxation and tax evasion
3. Definitions: Key terms used in the agreement including territorial scope
4. Residence: Rules for determining tax residence
5. Permanent Establishment: Definition and scope of permanent establishment
6. Business Profits: Taxation rules for business income
7. Methods of Elimination of Double Taxation: Mechanisms to avoid double taxation
1. Shipping and Air Transport: Special provisions for international transport when significant maritime or aviation operations exist between parties
2. Associated Enterprises: Transfer pricing provisions for cases involving significant related-party transactions
3. Non-discrimination: Equal treatment provisions when specifically requested by either party
1. Protocol: Additional agreements or clarifications to the main agreement
2. Exchange of Information Protocol: Detailed procedures for information exchange between tax authorities
3. Limitation of Benefits: Anti-abuse provisions and qualifying criteria for treaty benefits
4. Technical Notes: Explanatory notes on implementation and practical application
Authors
Resident
Permanent Establishment
Business Profits
Dividends
Interest
Royalties
Capital Gains
Professional Services
Fixed Base
Associated Enterprises
National
International Traffic
Competent Authority
Tax
Person
Company
Enterprise
Enterprise of a Contracting State
Fiscal Year
Territory
Political Subdivision
Local Authority
Beneficial Owner
Income from Employment
Director's Fees
Pension
Government Service
Student
Management Fees
Technical Fees
Property Income
Immovable Property
Connected Person
Place of Effective Management
Taxes Covered
Residence Rules
Permanent Establishment
Business Profits
Shipping and Air Transport
Associated Enterprises
Dividends
Interest
Royalties
Capital Gains
Income from Employment
Directors' Fees
Artistes and Athletes
Pensions
Government Service
Students
Other Income
Elimination of Double Taxation
Non-discrimination
Mutual Agreement Procedure
Exchange of Information
Diplomatic and Consular Privileges
Anti-abuse Provisions
Entry into Force
Termination
Technical Services
Limitation of Benefits
Assistance in Collection of Taxes
Territorial Extension
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