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Thai government to tax all income from abroad for tax residents starting 2024

theblast3r

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Mar 12, 2022
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I am even reading that it would be not only the money remitted into Thailand, but worldwide income

That's correct. Thailand it's not a territorial taxation country, it follows residence based taxation.

They had this "if you remit income from abroad after 1 years it's tax free" loophole but if now they removed the loophole it's residence based taxation for all, thanks to CRS.
 
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Full tweet reads: ‘New interpretation under the New Order:
According to the New Order, if Thai tax resident individuals derive offshore-sourced income and bring offshore-sourced income into #Thailand, they will have to pay Thai personal income tax, regardless of whether such income is brought into Thailand in the calendar year of receipt or in subsequent calendar years.
The New Order will apply to any taxable income that is brought into Thailand from 1 January 2024 onward. Any regulation, instruction, revenue ruling or practice which is contrary to or inconsistent with this New Order shall be repealed.
It is noteworthy that if the offshore-sourced income is not a taxable income (e.g., proceeds from the sale of offshore securities or assets with no gain) or income that is exempted from Thai personal income tax under the Revenue Code, such as income from insurance, Thai tax residents will not have to pay Thai personal income tax when they bring that income into Thailand.’
 
Global Income remitted...
Then it shouldn't be a major problem. Have your assets and income generated offshore and either bring some minimal income to be taxed (after DTT) or just take a loan/remit as much as you can in 2023 and live tax-free after. It's basically a non-dome regime without any limitation. Don't have enough? Lose the tax residency in Thai (<180 days), then remit as much as you want as non-resident, then become a tax resident again.
 
So what is it?

Nobody knows for sure BUT i don't think it's a coincidence that if they implemented this change immediately after adopting CRS. Now they will receive informations about all tax residents foreign bank accounts.
 
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