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HMRC internal manual

Double Taxation Relief Manual

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HM Revenue & Customs
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DT: Thailand: double taxation agreement, Article 18: Artistes and athletes

(1) Notwithstanding the provisions of Articles 15 and 16, income derived by publicentertainers, such as theatre, motion picture, radio or television artistes, andmusicians, and by athletes, from their personal activities as such may be taxed in theContracting State in which those activities are exercised.

(2) Where income in respect of personal activities as such of an entertainer or athleteaccrues not to that entertainer or athlete himself but to another person that income may,notwithstanding the provisions of Articles 8, 15 and 16, be taxed in the Contracting Statein which the activities of the entertainer or athlete are exercised.

(3) The provisions of paragraphs (1) and (2) of this Article and paragraph (4) of Article5 shall not apply to remuneration or profits, salaries, wages and similar income derivedfrom activities performed in a Contracting State by public entertainers if the visit tothat Contracting State is substantially supported by public funds of the other ContractingState, including any political subdivision or local authority thereof.