This document is a technical explanation of the Convention between the United States and Thailand which was signed on November 26, 1996 (the "Convention"). References in this Explanation to the "U.S. Model" are to the United States Model Income Tax Convention, published on September 30, 1996. The U.S. Model was published following negotiation of the Convention, but the Convention reflects substantial consistency with the language and policies of the U.S. Model. References to the "OECD Model" are to the Model Tax Convention on Income and on Capital, published by the OECD in 1992, as subsequently amended. References to the "U.N. Model" are to the United Nations Model Double Taxation Convention between Developed and Developing Countries, published in 1980. The Technical Explanation is an official guide to the Convention. It reflects the policies behind particular Convention provisions, as well as understandings reached with respect to the application and interpretation of the Convention.