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Mario is a very respectable source for TH, number 1 source for German speakers IMHO. Apparently this seems to be the PLAN for the near future regarding immi. Thai plans are however prone to suddenly change or being aborted as Mario mentioned also. I think there is really no way to predict anything currently regarding tax.

I agree with almost everything. The only item that crossed my mind is that non O and non OA visa holders would not be shown on TRD radar. You could go back to back with those visa for many years. However you would still commit tax evasion if you would not hand in a tax declaration. I thought a lot of the planned changes unthinkable just 2 weeks ago...

Corrected

The 1 Billion is in regard to companies i.e. plattforms like Grab, Ebay etc. I assume TRD wants info on what Somchai sold on Ebay or earned as a Grab driver. Same happened in my country Germany. Ebay has to report all income above a certain threshold directly to the German IRS.

Sure they can, however I think highly unlikely but I assume anything is possible now. Especially as it is not 180 days plus currently in the year 2024 so they could argue that is not retroactive or that it is just a new interpretation of an existing law (happened several times in Germany that the interpretation of a law changed and was applied retroactively). But maybe a translation error of the newspaper, overstepping of TRD chief etc. No one knows, all I am saying is be prepared for the worst in case you have some serious money on the line. Preparing for the worst means do not stay over 180 days in Thailand, if you are not prepared to pay Thai income tax on your ww income.

I recommend to google the following term "New overseas income rules" for an article that claims that ALL income (not just remitted!)will be taxed according to the head of TRD pending a law change. How and if that could change anything regarding LTR WP is beyond me.

Thank you for your reply. However I Jim Gant stated only 1 year was needed in his case for LTR WP. In my case a tax statement does not show the majority of my income anyway as it is taxed at source by the bank. Thanks to PiB also showing that only one year of proof seems to be enough as proof of income.

I understand the 1 Billion baht number as that for example Ebay has to report to the TRD the amount Somchai has made selling stuff on Ebay as Ebay has more then 1 Billion THB revenue. The 1 Billion is not directly connected to personal income tax .

I recommend to google the following term "New overseas income rules" for an article that claims that ALL income (not just remitted!)will be taxed according to the head of TRD pending a law change. So basically everything is now possible regarding income taxation. Even a ww taxation of funds that have not been remitted to Thailand. However I still suspect they will cancel or postpone the application of this change of law but who I am to know Thai politics. Pls google "New overseas income rules"

Very interesting and good to hear that they only want the last 12 months for LTR WP. How did you prove the last 12 months or is it last calendar year? Thanks! PS: If it is March I do not have any tax documents for the year before as an example.

I fully agree with your caution! Pls let us know what TRD answered you. My gut feeling is that the monies are safe but what do I know of the intrinsic working of thai politics, royal degrees and the Thai RD. Hell even when dealing with the german IRS I do not know 50% of the time what will be the final result as the laws are wide open for interpretation, even in Germany with loads of very detailed tax laws. To top it all off even if the law is clear the next day a german court decides the law has to be changed in retrospect or for all open tax declarations and bam (happened several times already).

In close to all countries only realized cap gains are to be taxed. Some consider even this a loophole. Germany does not have an "exit tax" if you own less then 1% of the company. The list of countries with an expatriation tax is very short and has a lot of loopholes even if the country has an exit tax, so consider yourself surprised 😉 https://en.wikipedia.org/wiki/Expatriation_tax NB: I am always suprised that people who are not subject matter experts have a strong opinion about the subject. 😉 no offense

Why would you want to close your account instead of keeping the balance close to zero? I assume the cost is not too high for keeping the account alive.

I am not a 100% sure it is considered a remittance. I think it might be classified as a remittance but it is far from sure. There was one representative of TRD who said so but no one knows for sure IMHO.

Thank you for the clarification! For the former german tax residents it is important that the 17% income tax rate is not applied as otherwise they would have maybe to pay more taxes in Germany even if they are no longer tax resident in Germany (erweitert beschränkte Steuerpflicht). So the LTR pensioner visa is perfect as offshore income is tax free and one does not get a preferential income tax rate.

I actually work in the international tax field so I hope you can trust my statements. This issue is not an DTA issue at all because there is only 1 country involved (Germany) when I leave. A lot of things regarding tax are handled completly different for each country. The moment I leave I am only resident of one country.

This is the way it is done in Austria with all share holdings (and apparently in CAN) but in Germany it is only appplied when you own more then 1% of a company and you leave the country. Quite a challenge to own 1% of SAP or Apple. However if you own more then 1% you have to pay the unrealized gains when leaving.

Do I understand correctly that the 17% income tax treatment is only applicable to highly skilled professional and not to wealthy pensioner LTR?

Good info there for the canadians! It works flawless in Germany and a lot of other countries that I know of. The only other country where it does not work that I know of is Austria until your post.

Great post! My 2 cents: 1: It is relatively easy to make capital gains happen i.e. you own a bunch of Meta or NVDA for 10 years, so you can choose when to sell and reap the capital gains. This is quite easy as I assume any person in his right mind would not reap cap gains while living in a high tax country and planing to live in TH (5 year mark). 2: I could not agree more that revealing large sums of capital is maybe not a good idea. I still remember when they "lost" all the data for the Phuket sandbox including passport numbers all bio info and maybe also the credit card info. The yield on us bonds is currently in the area of 4.5%. However I think TH is not Mexico ( a country I hold dear) and the risk of being kidnapped is very low to my knowledge in TH. I also think being rich in TH starts at a very early point for us westerners and any LTR wealthy pensioner is considered wealthy 😉 I do not really like the LTR stamp (some LTR categories) in my passport that shows I am rich to every hotel employee.

The question and your answer added substantial value to this thread. I do not have a clue why you want to delete these posts.

Mike to be frank your way of approaching this topic is very different then mine. I think your strict approach is not helpful because there will not be a consensus on 50% of the topics and therefore they cannot be "closed" out as there is no specific law or directive for a lot of issues. You long for the one correct answer like in mathematics but TiT and we are talking tax law which is evolving in a constant matter.

There is currently no indication whatsoever that TH will change to a ww income taxation let alone change a royal degree for LTR visa holders. It is not even clear that they will verify the implementation of the new directive regarding remitted monies. Anyway under CRS TRD is already receiving info on all ww income anyway (exemption being US accounts IMHO).

It was my understading that they check 2 years (only) backwards at the 5 year mark, and that should be no problem (for me). At the 5 year mark there will be no thai tax document as capital income is not taxable per definition of the LTR visa so I hope Bank statements will be OK. If you are also a tax resident of another country you would have a tax document but that should be the exception IMHO for LTR visa holders.

Thank you for your feedback! Could you kindly elaborate what makes you think that cap gains could pose a problem for BOI? Do you have any negative experience? Thanks! NB: There is nothing easy about a German tax declaration. There are 5 different types of capital gains alone and several types of income. No way to explain this, even to a translator. I can try yes but would like to know how likely it is to get the income accepted, before I spend 3 days + on this, while having ample resources at several banks. However BOI wonders if I have enought to spend 5 years in TH. 200K USD per year=1 Mio USD should really do the trick but TIT I know.