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HMRC internal manual

Double Taxation Relief Manual

DT: Thailand: double taxation agreement, Article 16: Dependent personal services

(I) Subject to the provisions of Articles 19 and 21, salaries, wages and other similarremuneration derived by a resident of a Contracting State in respect of an employmentshall be taxable only in that State unless the employment is exercised in the otherContracting State. If the employment is so exercised, such remuneration as is derivedtherefrom may be taxed in that other State.

(2) Notwithstanding the provisions of paragraph (1) of this Article, remuneration derivedby a resident of a Contracting State in respect of an employment exercised in the otherContracting State shall be taxable only in the first-mentioned State if:

(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the fiscal year concerned; and
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.

(3) Notwithstanding the preceding provisions of this Article, remuneration in respectof an employment exercised aboard a ship or aircraft in international traffic may be taxedin the Contracting State in which the place of effective management of the enterprise issituated.