Can LTR visa holders legally work remotely from Thailand for a foreign employer without tax implications?

@Neil *****

As a lawyer how would you interpret the meaning of "habitually" in the context of the section on PE in the UK-Thailand tax treaty (though I think similar wording in other tax treaties(, where it refers to an employees role in revenue generation or sales. Basically if you are involved in a sales transaction that involves a Thai client entity, then there is PE, unless that is not an habitual role. That includes contract signing on behalf of the company. Anyone in senior management could be asked to do that. Anyone hoping for career progression could do that. Basically the LTR restricts what you can do for your employer. I don't even know what means for employment rights in terms of redundancy. And the only person wanting to be in Thailand is the employee. There is no incentive on the employer to make this work unless they wanted to retain the employee, and that means senior management only. Everyone else is expendable. I've had conversations withe a senior tax law expert in a Hong Kong based merchant bank who knows a thing or two about international tax law and had a completely different view of this. What's more, Thailand can change their mind in 5 years time and those people who thought they were there for 10 years aren't. Name these global firms who are on board with shipping out senior managers to Thailand under this scheme. Virtually all senior managers in a public company are directly involved in revenue generation. Thailand require furnishing of accounts show no sales in Thailand otherwise they can levy a 5% charge.