I know you don't speak the King's English Nigel, but I would have thought that this is pretty clear, even for a Yank Article19 Governmental Services (1) (a) Remuneration, other than a pension, paid by a Contracting State or a political subdivision or a local authority thereof to any individual in respect of services of a governmental nature rendered to that State or subdivision or local authority thereof shall be taxable only in that State. (b) However, such remuneration shall be taxable only in the other Contracting State if the services are rendered in that State and the recipient is a resident of that other Contracting State who: (i) is a national of that State; or (ii) did not become a resident of that State solely for the purpose of performing the services. (2) (a) Any pension paid by the Contracting State or a political subdivision or a local authority thereof to any individual in respect of services of a governmental nature rendered to that State or subdivision or local authority thereof shall be taxable only in that State. (b) However, such pension shall be taxable only in the other contracting State if the recipient is a national of and a resident of that State. As I said, UK pensioners with no earnings in Thailand are NOT taxable here