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ARTICLE 8

U.S. Income Tax Treaty — Thailand Income Tax Treaty - 1996 · 2026-10-03 edition · updated 2026-10-04 · United States

Shipping and Air Transport

  1. a) Income or profits which a resident of the United States derives from the operation of aircraft in international traffic shall be taxable only in the United States.

b) Income or profits which a resident of Thailand derives from the operation of aircraft in international traffic shall be taxable only in Thailand.

  1. a) The amount of tax imposed by Thailand on income or profits derived by a resident of the United States from the operation of ships in international traffic shall be reduced to 50 percent of the amount which would have been imposed in the absence of this Convention.

b) The amount of tax imposed by the United States on income or profits derived by a resident of Thailand from the operation of ships in international traffic shall be reduced to 50 percent of the amount which would have been imposed in the absence of this Convention.

  1. For the purposes of this Article, income or profits from the operation of ships or aircraft in international traffic include income or profits derived from the rental of ships or aircraft if such rental profits are incidental to other income or profits described in paragraphs 1 and 2.

  2. Income or profits of an enterprise of a Contracting State from the use, maintenance, or rental of containers (including trailers, barges, and related equipment for the transport of containers) that are incidental to income from the operation of ships or aircraft in international traffic shall be treated for purposes of paragraphs 1 and 2 as income from the operation of ships or aircraft in international traffic.

  3. The provisions of paragraphs 1, 2 and 4 shall also apply to income or profits from participation in a pool, a joint business, or an international operating agency.

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▸Contents — U.S. Income Tax Treaty — Thailand Income Tax Treaty - 1996
U.S. Income Tax Treaty — Thailand Income Tax Treaty - 1996

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