Absolutely. I personally see this as a power play by the Director of TRD. Some Thai governmental officials love power. And like to make a name for themselves.
MaoTseTung said something along the lines of" just because you have the power to make a ruling, doesn't necessarily make it right to invoke it, just because you can.
I understand her rationale, but I really don't think it will affect the majority of expat retirees with DTAs. After all there is also a huge number of working Thais, who also don't pay tax.
Finally, I think that this resurgence of an existing income tax regulation was designed for some of those people in Thailand ( Thais and foreigners) bringing in large profits from overseas investments without declaring them to TRD. Hence this " (one Size fits all) sledgehammer ruling to crack a nut.
But I stand to be corrected.😁
Personally, I will not be leaving Thailand before the 180 day ruling. I'm happy enough to resolve any possible tax implications, as and when and if they arise.