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Posted
If an German national resident in Thailand holds UK listed equities in a US brokerage account, which DTA is applicable to the dividend income? Germany-Thailand, UK-Thailand or US-Thailand?

Thanks
Posted

Or would it be where the tax was being paid or more to the point where you complete a tax return (if you do....)?

Posted

Germany-Thailand
 

I suppose you have been, or you still are, resident in Germany and never been resident in UK or USA.

 

The article 1 of your DTA says :


    This Agreement shall apply to persons who are residents of one or both of the Contracting States.
 

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