Thailand - Employment

Article 15. Personal services

Taxation residence state

1. Subject to the provisions of Articles 16, 18, 19, 20 and 21, remuneration derived by a resident of one of the States in respect of personal services (including the practice of a liberal profession) shall be taxable only in that State unless the services are rendered in the other State. If the services are so rendered, such remuneration as is derived therefrom may be taxed in that other State.

Taxation source state

2.  Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of one of the States in respect of such services rendered in the other 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 net exceeding in the aggregate 183 days in the fiscal year concerned, and 

b  the remuneration is paid by, or on behalf of, a person who is not a resident of the other State, and 

c  the remuneration is not borne by a permanent establishment which the person paying the remuneration has in the other State. 

Employment at ship or aircraft

3. Notwithstanding the preceding provisions of this Article, remuneration in respect of an employment exercised aboard a ship or aircraft in international traffic, may be taxed in the State in which the place of effective management of the enterprise is situated.