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Thai Tax: Comparing the American and British Double Tax Treaties?

Transcript of the above video: 

As the title of this video suggests, we are discussing the Double Tax Treaties of both the UK and the United States and their interaction with relevant Thai Law. I thought of making this video after reading a recent article in the Pattaya Mail, that is pattayamail.com, the article is titled: Thai lawyer downplays expat Visa awards versus personal taxation worries. Quoting directly: "Double Taxation Treaties are also relevant according to Professor Suthasinee Piriyakijkomol, a tax auditor and associate judge of the Labour Court. "The agreements differ country by country, but my advice is to keep a detailed record of tax paid in the home country as this can be used, if need be, to offset any future TRD demands (TRD is Thai Revenue Department)," she said. She agreed that some agreements were more detailed than others on personal taxation. For example, the American Treaty is more detailed on US Pension or social security income, and where it should be paid, than the British one." 

The fact of the matter is all Double Tax Treaties differ if only in some ways, but in some cases in very radical ways. Now the UK and the US's Double Tax Treaties are similar, but they are similar in the same way that British Common Law or Westminster Law is similar to American Law. Yeah, same, same but different as we would say here in Thailand. Look the analysis regarding liability depending on your nationality, depending on the origination point of any funds or income, and then how that interacts with the British and American Tax Treaties, that will all be dictated by the underlying facts in the given case.

So, the thing to take away from this video and understand is all Double Tax Treaties are not created equal; they do differ. The US and the British Double Tax Treaties with Thailand differ markedly, so the analysis regarding one's tax liability will differ depending on if you come from either one of those countries, and again if the funds coming to you originate from either one of those countries coming into the Kingdom of Thailand.