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HMRC internal manual

Double Taxation Relief Manual

DT: Thailand: double taxation agreement, Article 9: Air transport


(1) Income from the operation by an enterprise of a Contracting State of aircraft in international traffic shall be taxable only in the Contracting State in which the place of effective management of the enterprise is situated.

(2) The provisions of this Article shall likewise apply to the share in respect of participation in aircraft pools of any kind by such an enterprise engaged in air transport.