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HMRC internal manual

Double Taxation Relief Manual

Thailand: Source of income

For the purposes of the credit Article, profits, income and capital gains owned by a resident of the United Kingdom which may be taxed in Thailand under the provisions of the agreement are deemed to be income or gains from sources in Thailand (Article 23(4)). Interest and royalties are deemed to arise in the country of which the payer is a resident (Articles 12(6) and 13(5)).