It seems even the experts are just as confused (per email from Expat Tax). The head of the Revenue Department needs to sit down, discuss with advisors, make an unambiguous decision, and publish it. We've had 21 months of ambiguity, panic, contradictory information from the Revenue Department staff in different offices, or even the same office, most completely untrained in the nuances of DTAs etc. This Thai Examiner article is certainly more detailed than the BP article, which made a confusing situation more confusing. The writer of that one may need to consider another career choice. But none the less, until an unambiguous decision is made (and enacted in law and published in the Royal Gazette), the result of uncertainty that has ensued is now all too visible to see, through the reduction of tax revenue by THB20 Billion. Until it is, that figure could certainly go northwards.