Withholding tax on dividends limited when paid to a foreign resident, subject to permanent establishment and source-state rules.

Article 10 limits taxation of dividends under the Thailand DTAA: dividends may be taxed in the recipient's State and also in the source State, but where the beneficial owner is resident in the other Contracting State the source State's tax on the gross dividend is capped at 10 percent; this does not affect taxation of the company's profits. Dividends include income from shares and similar corporate rights. Relief does not apply where the beneficial owner's holding is effectively connected with a permanent establishment or fixed base in the source State, in which case rules on business profits or independent services apply.

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