Here's Article 4. Australia will have primary taxing rights, because the income is generated in Australia. Article 4 Residence 1. For the purposes of this Agreement, a person is a resident of one of the Contracting States: (a) in the case of Australia, if the person is a resident of Australia for the purposes of Australian tax; and (b) in the case of Thailand, if the person is a resident of Thailand for the purposes of Thai tax. 2. A person is not a resident of a Contracting State for the purposes of this Agreement if the person is liable to tax in that State in respect only of income from a source in that State. 3. Where by reason of the preceding provisions, an individual is a resident of both Contracting States, the status of the person shall be determined in accordance with the following rules, applied in the order in which they are set out : (a) the person shall be deemed to be a resident solely of the Contracting State in which a permanent home is available to the person; (b) if a permanent home is available to the person in both Contracting States, or in neither of them, the person shall be deemed to be a resident solely of the Contracting State in which the person has an habitual abode; (c) if the person has an habitual abode in both Contracting States, or in neither of them, the person shall be deemed to be a resident solely of the Contracting State with which the person's personal and economic relations are the closer. 4. For the purposes of the last preceding paragraph, an individual's citizenship or nationality of a Contracting State shall be a factor in determining the degree of the person's personal and economic relations with that Contracting State. 5. Where by reason of the provisions of paragraph 1, a person other than an individual is a resident of both Contracting States, it shall be deemed to be a resident solely of the Contracting State in which it is incorporated, created or organized. This lady explains it very well, with some examples. There are over 1200 comments, many of them disagreeing with members on this forum, who prefer to practice The Ostrich Method. 😂 Now, is it an AI video? Is it fake news? Is she lying? Is she inaccurate?