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HMRC internal manual

Double Taxation Relief Manual

DT: Thailand: double taxation agreement, Article 6: Limitation of relief

Where under any provision of this Convention income arising in one of the ContractingStates is relieved from tax in that Contracting State and, under the law in force in theother Contracting State a person, in respect of the said income, is subject to tax byreference to the amount thereof which is remitted to or received in that other ContractingState and not by reference to the full amount thereof, then the relief to be allowed underthis Convention in the first-mentioned Contracting State shall apply only to so much ofthe income as is remitted to or received in the other Contracting State.