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HMRC internal manual

Double Taxation Relief Manual

DT: Thailand: double taxation agreement, Article 15 Independent personal services

(1) Where a resident of a Contracting State derives income from the other ContractingState in respect of professional services or other independent activities of a similarcharacter he shall be subject to tax in that other State but only in respect of such partof that income as is attributable to his services in that State. In determining the incomeattributable to such services, there shall be allowed as a deduction expenses incurred inthe performance of those services including reasonable administrative and general expensesso incurred, whether in the State in which the services are performed or elsewhere.

(2) The term `professional services` includes especially independent scientific literary,artistic, educational and teaching activities as well as the independent activities ofphysicians, lawyers, engineers, architects, dentists and accountants.