Treaty detail
China - Thailand tax treaty
A practical treaty page built around the official treaty text, key withholding categories, permanent-establishment rules, and article-level summaries.
Signed
1986-10-27
Effective
1987-01-01
Articles seeded
6
Withholding snapshot
Dividends
Individual rate: 20% · Corporate rate: 15%
The China-Thailand treaty is one of China's older treaties and applies a relatively high cap on cross-border dividends. The precise outcome depends on beneficial ownership and Article 10.
Interest
Rate: 10%
Interest paid to or guaranteed by the government or central bank of either state, and certain interest received by financial institutions, may benefit from a reduced rate or exemption under Article 11.
Royalties
Rate: 15%
Royalty treatment under this treaty is article-specific. The 1986 treaty includes higher rates than China's later treaties. Practitioners should confirm the rate against Article 12, particularly for technology and equipment royalties.
Permanent establishment
Construction threshold: more than 6 months
Dependent-agent rules apply where a person habitually concludes contracts or maintains a stock of goods on behalf of the enterprise, consistent with the older UN-influenced template.
Other treaty flags
Pension taxation is generally allocated to the residence state, with separate rules for government-service pensions.
Seeded article summaries
Article 4
Residence
Defines treaty residence and is the gateway to any benefit under the treaty.
Residence under the China-Thailand treaty is particularly relevant for Belt and Road project structures, regional sourcing operations, and expatriate workers.
Article 5
Permanent Establishment
Sets the business-presence threshold with a services-PE element.
The China-Thailand treaty follows the older UN-influenced template and includes both a construction threshold and a services threshold, which often drives the PE outcome for short-term consulting engagements.
Article 7
Business Profits
Reserves business profits to the residence state absent a permanent establishment in the other state.
Article 7 is the operating rule for cross-border services, distribution, and operating subsidiaries between China and Thailand. Once PE is ruled out, business profits are generally taxed only in the residence state.
Article 10
Dividends
Provides the treaty cap on cross-border dividend withholding.
Article 10 produces relatively high caps compared with China's later treaties. The article should be read together with each country's domestic withholding rules and any administrative guidance.
Article 11
Interest
Caps source-country withholding on cross-border interest with government-interest carve-outs.
Article 11 caps the general rate at 10 percent. Government-related and qualifying financial-institution interest may be exempt or subject to a reduced rate.
Article 12
Royalties
Caps source-country withholding on royalties at a rate higher than in modern OECD-style treaties.
Royalty rates under the China-Thailand treaty reflect its 1986 vintage. Practitioners should confirm the rate against Article 12, with particular attention to the treatment of industrial, commercial, and scientific equipment use.
Official text
Other treaties involving these jurisdictions
Computed from the cross-reference graph. Links open the related entity on this site.
This entry cites
- TreatyUS–CN treaty
- TreatyGB–CN treaty
- TreatyCA–CN treaty
- TreatyAU–CN treaty
- TreatyCN–DE treaty
- TreatyCN–JP treaty
- TreatyCN–IN treaty
- TreatyCN–SG treaty
Primary sources
- China State Taxation Administration - tax treatiesVerified 2026-05-20
- Thai Revenue Department - international taxationVerified 2026-05-20
- OECD MLI signatories and partiesVerified 2026-05-20
Important disclaimer
This library is for general tax education only. Always verify filing obligations, due dates, and tax consequences against the cited primary source or with a qualified tax professional.