The Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income between Hong Kong and Thailand was formally signed on 7 September 2005. The Agreement entered into force on 7 December 2005.
After the Agreement became effective, the Hong Kong business sector has doubt whether the profits remitted to a Hong Kong head office by a branch office in Thailand is subject to tax in Thailand. On 21 February 2008, the Hong Kong Special Administrative Region Government replied to the Note from the Thai Government and confirmed the understanding that either Party shall not impose a tax on profits remitted by a permanent establishment of an enterprise of the Other Party.
The Note from the Thai Government and the captioned Note from the HKSAR Government shall form an integral part of the Agreement and shall enter into force on the date that the Agreement entered into force, that is, 7 December 2005.
Please click here for the Note from the Government of the Hong Kong Special Administrative Region to the Government of the Kingdom of Thailand dated 21 February 2008.