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I was assuming /apparently wrongly) that you have no other tax residency other then TH so yes you are right your case may be different. Usually you only have one tax residency as most countries use the 183 day rule (AUS, US seem to be the exemption; Germany can be in some cases as well if you still have an abode in GER). On what ground does AUS rule you to be an AUS tax citizen? I think most expats with the exception of the US guys only have one tax residency as they cannot stay more then 183 in another country if they have already stayed 183 in TH. It is my understanding that the Thais can claim income tax from you all the same if the DTA does not prohibit it. In case of GER TH the DTA explicitly states that TH has the right to tax me if I live in TH and have not lived 183 in GER, no idea though about Australian DTA. Especially if you have no other tax residency (or income from the other state) TH can tax you as they please according only to their law. They could for example make up a wealth tax of 10% p.a. and charge it. Every country can make up their own law as you can see in North Korea, Iran etc no matter how outrageous it may seem to us westerners and give us nothing in return. Again I still think TH will not collect or apply these taxes US IRS style but they could.

Thailand can of course tax your worldwide income, if you are a tax resident as the majority of countries do worldwide. The only thing that could stop them would be a DTA but even in most DTAs it is stipulated that the country of (primary) residence aka TH has the right to tax them. I am afraid your legal status (dual pricing, right to vote, free healthcare etc) in TH does not change a thing about the right of taxation. If they will enforce this RD directive in real life is of course a different topic and no one yet knows.

You would have to pay the normal income tax on it, if the directive will be applied as planed (big if I agree)

Very safe to do so yes. Has there ever been anyone indicted for piracy via public torrents in Thailand?

I fully agree with Dogmatix! Why not make the tax guide a sticky item for quick reference (if possible). The guys who want the deep dive need the thread. This taxation issue is a complicated topic so there are no quick answers and a lot of fears and misconceptions which should be adressed in this specifc thread. Thanks to George that he has reopened the thread!

Are you even sure the DTA applies to you and your form of income? If you have cap gains in France from US shares and you do not live any longer in France the DTA is not relevant for you, just as an example.

It is assesable to be precise... It is only taxable if 100% of the amount transfered is profit that arose in 2024

I could not agree more. Prepare for the worst and be happy if the law is not applied/controlled which is likely IMHO.

spot on correct, as there is not data on international remittanced in crs, but the cyclist can't be bothered to admit that he is wrong (again). Crs info does not even show if and how much profit you made, it just shows that you have received amount x by selling share y.

So they were checking that you payed taxes in order to get an extension? If just the witholding tax is sufficient that would be great news . You do not get around the withholding tax on dividends anyway in most cases. Thanks for any clarification!

Tax is levied on worldwide! not just remitted income in Cambodia. A 20 sec google search would have shown it. So if you pay at source, cambodia and TH are the same regarding your pension but NOT regarding other investment income so TH wins hands down.

The law has not changed just the interpretation! I agree it is not nice and the effect is the same as a new law would have, but it is what it is. Happend in several countries before, nothing anyone could do about it, especially as we are both foreigners in Thailand .

No offense but maybe you should read more and post less ...

Another amazing post Ahem cambodia taxes your worldwide income way higher then Thailand... NB: I am talking of course of the legal obligation to pay taxes not if you chose to go rogue etc.

Did it ever occur to you that some people here work in tax consultancy?

Sorry man apparently you do not want to understand that this is possible in most countries. The interpretation of a law changed and therefore it is considered to NOT be retroactively. Happened in Germany a lot of times, of course always in tax laws benefitting the state.

I was nowhere stating that the banks will tax it at source with a withholding tax. I was talking about a LEGAL obligation to file a tax return and then be obliged to pay taxes.

Theoretically yes they could but would never do it as they would lose out a lot of business investments from the US. DTAs are usually decades old and are only changed in minuscule details. For example DTA between Thailand and Germany is from 1968.

There is simply no way to tax 35% on every ATM transaction, as you become retroactively tax liable only after living 180 days in TH. However very very slim chance of taxing after day 180. There is not much more to do or say after Thai RD gives further clarifications either by statements or by their work in 2025.

While I agree that there is a 50% percent chance (just my gut feeling) that TH will not tax 2024 remittances because they cannot tax it or they do not want to tax it, the problem remains that some people could be liable to pay half a million or more of USD in taxes and no agent could rid you LEGALLY of this obligation. I fail to understand why you think there are no "rich" guys on this forum or in TH. Just check the LTR thread and read the requirements for the HNWI. If you "only" send 15-20K USD a year, the risk is not that big as you stand to lose less, but this money could be a lot for people who rely on this money to pay for their well earned retirements.

Correct the majority of Germans that life fulltime in TH currently get their pension tax free as TH is not exercising its DTA right to tax German persions. Some company pensions are taxed in Germany. NB: Anyway the vast amount of German pensions is generated by taxed income and is just a principal payment.

Why should pensions be exempt if the DTA (GERMAY TH for example) states clearly that the pension should be taxed in Thailand? However TH never bothered to tax the pensions in the past.

Thanks for your post! I see your line of reasoning now. However the differences are in my opinion: Apparently you will have to file a tax return for 2024 and RD will check and tax your 2024 earnings if remitted to TH. To my knowledge before 2024 there was no (real life) check from RD if you really remitted only gains from previous years. You can no longer remit your 2024 gains in 2025 or later tax free, you have to leave your 2024 gains outside of Thailand forever or not be a tax resident in a given year to remit without being taxed. So if you have 2024 cap gains you will have to pay tax on your gains sometimes in the future (if you remit or cannot prove they have been taxed elsewhere).

@Mike ListerJerry is right on this one, there are a lot of countries that do not use the 180/183 day rule and therefore you can be tax resident in 2 or more countries. Another example: in Germany you are a tax resident if you have an abode in Germany. A garage with water and electricity that you could use to live in is sufficient. Even if you have not spend a second in Germany you are considered a tax resident for the whole year. @Mike Lister No offense pls abstain from posting on issues where you have not checked the factuality in detail. It comes as a surprise to me that you have worked in the big 4, but my guess is not in a tax consultant role. I know a lot of big 4 audit and consulting partner who do not have a clue about taxes and openly admit it because they work in other fields.

This is the way it is in the PH once you stay longer then 6 months. However seems to be a relative easy and fast process that can be done within hours.