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Really under 560K Baht p.a.? This is not even enough for the extension of stay in TH via the income method. Maybe I am mistaken but I assume that the majority here are over 560K Baht per year.

I agree with Presnok: They COULD simply draw up some rules that defacto makes the exemption worthless as you cannot provide the documents that give you the exemption. For example provide a document from your government that the remitted amount has been taxed. Unlikely but possible. My gut feeling is that you will be able to simply self assess and no one will make a fuss about it, but that is far from certain or a safe way for people with 6 digit capital income p.a. I fear there will be no watertight clarification from TRD in the near future neither for the LTR visa nor for the taxation questions in general.

It is my understanding that if they want to implement ww taxation they must announce before Jan 1st 2025. They could make a waterproof announcement regarding the tax exemption for LTR in theory but I think we all agree that this is unlikely. This is why I hoped for that lots of people would ask BOI so that first BOI understands the necesity of a clarification and b asks the right people for a clarification (TRD, governement) etc. It would really be a shame if the LTR were to be completly tax exempt and people left TH because no clarification was given. Godspeed!

Even the US acknowledges international law and treat DTA like US law. https://2001-2009.state.gov/s/l/rls/86123.htm The US is one of the few countries that could say "I do not care " but even they do care and oblige to their international agreements like DTAs, investment agreements etc. It is very rare that a law is changed retroactively worldwide so if TH/BOI states in a royal degree all income is tax exempt in 2025 this is as sure as it gets, they could do it if they want to, but apparently they do not want to do it. Of course you are right and they could ruin their international standing and do what they want renegging on their promises and international treatments but very few governments have ever done it.

Perfectly viable to live in 3 countries and not be a tax resident in one of them. Applying for a visa should be hassle free as they usually ask to state a residence not a tax residence. However you should not claim preferrential tax rates that are stipulated in DBAs as you do not have a tax residence, if the banks check these things is another matter.

I was pointing out that you initial post was wrong and that there are legally binding contracts and documents that a new government cannot change. So your claim that those never exist is just plain wong. Just because you have never heard of it does not indicate that these do not exist. Example: https://www.bzst.de/DE/Unternehmen/VerbindlicheAuskuenfte/verbindliche_auskuenfte_node.html#js-toc-entry4 Again that BOI is not willing to say something just indicates how bad the situation for us expats can get. As much as I like the US, some of their citizens seem to be completly unaware how different the rest of the world works or does not. 😉

If you do not get an answer from BOI it is an answer in itself. In this case you know that there is currently no guranteed tax exemption of unremitted income in 2025 and forward. There might be a tax exemption also for unremitted income. However BOI did answer the question of remitted income. So it is not a waste of time asking questions. There are a lot of examples in other countries where you get a definite and legally binding answer from the officials concerning future tax treatment.

You are in the right! CRS/Fatca does not track transactions, it tracks aggregated volumes and account balances. However they could ask the thai banks to provide data on cc transactions however I doubt that will happen in 2025. In addition I currently see no way they could link John Smith as being the John Smith in Phuket or the Joe Smith in Leeds, maybe use one cc with your old adress at your home bank, however you are obliged legally to update your info 😉.

If you think you have understood for sure how DTAs work you have not understood them.

DTAs are usually quite similar so you could learn from the Aussie discussion. It takes 1 sec to check if a post is AUS specific and skip it, so no problem IMHO.

Thailand is hands down my favorite country to live in. As long as the ww income taxation does not come into beeing I will chose TH as I could live with the remittance taxation and simply live off just from gifts from my relatives. I agree with all of the points you mentioned about the LTR, LTR is the best visa if you are sure you will stay the 10 years. Peace of mind is very important to me and the LTR does just that. If I would be sure that everything stays the same in TH in the next 10 years (no upheavels, no tax scares, no changes in personal situation etc) the LTR wins hands down. Self insurance was a valid point for me but then I came across a german health expat insurance for 69€ per months (up to 65 and you have to live in GER before) that is accepted by the Thai authorities. The thai insurances were a joke in my view as they did not provide sufficient coverage and were expensive in regards to their coverage. I am really happy that I can watch from the sideline how this tax scare plays out. Hopefully in Mid 2025 we will see the impact of the new rules and if LTR visa gets a full tax exemption which I hope for.

I will not be in TH at all, as long as the tax issue is not clear. The O-A visum seems like a good option as it allows for close to 2 years in TH. With his tax issue I do not think planing in decades makes any sense for me so I would not spend 50K for a 10 year visum instead I would rather spend 175€ for a 2 year visum. If tax exemption comes to pass on all income, the LTR visum is a no brainer. Again this applies only for people with substantial offshore income who are concerned with their tax bill.

Sorry Johnny you are wrong. If you are on an LTR visum and you remit income your income is free (hopefully). If you are on any other visa in TH it is not. There is not really a need for a visum if you intend to stay under 180 days so I assume you are a tax resident anyway if we are talking visa. So here is an example that the visum type determines your tax bill (if 180 days plus in TH). However the main question at least for me is not the difference between visa IN Thailand it is between a visum in Thailand and between a visum in another country with substantial tax advantages. Again if you have substantial offshore income the tax situation is important. I assume that the majority of people who have at least 80K passive income are concerned about a potential 6 figure tax payment.

There seems to be a missunderstanding. I am not criticising anyone with an LTR Visa, far from it. My point is solely that if taxes are a concern for you the future tax situation is unclear in Thailand if you hold an LTR visa or plan to get one. There were some people claiming that no matter what will happen in 2025 the LTR will gurantee tax exempt status even for unremitted income, which is currently unclear. My main concern is tax but that only applies to myself, each to their own! For my personally TH is no longer a country that I will stay in longer then 180 days if I have to pay 6 figure taxes p.a. when other countries are next door without taxes.

There is only an LTR wealthy Global citizen not a DTV IMHO.

While I see your point, it is not unreasonably for them to give the answer that currently there is no blanket exception for unremitted income SHOULD ww income taxation come into place. In lots of jurisdictions you get a gurantee or contract that income is tax exempted or taxed at 10% etc no matter what. It is up to BOI to talk to TRD and find out what is what. Apparently they cannot do that or they already know the answer because it is negative. Either way the issue is open and no one should count on the RD to exempt unremitted income in case of an LTR visa that is all I am saying. If one is willing to pay 50K baht for an 10 year visa with an unclear tax status that is highly risky if you have substantial foreign income and care about your tax bill. I am sure as hell not going to pay for a visa and then have higher taxes (35% marginal tax rate) as in the developped worlds WITHOUT even being able to substract my cap losses from the gains. This could lead to paying 200.000K USD p.a. on a real world trading loss for anyone active in the stock market.

Ok from my point of view, I just glance over it. Sometimes there are things that apply to all nations but agreed 90% of the stuff not relevant for non aussies.

Feedback from BOI that others have gotten was to ask Thai RD. No farang (me included) can fathom which faction in the Thai government has the final say. Only thing we can currently state is that is unclear if unremitted income will be taxed, IF ww taxation would come into play. I have been loughed at numerous times when I brought this topic up several months ago. Now it is obvious that the taxation issue is unclear, despite the royal decree as the rd "only" explicitly covers remitted income.

As mentioned before I asked BOI several times the question about taxation of unremitted income and they did not answer. Pls ask them yourself to make them aware that this is a central pillar as you correctly mentioned of the allure of the LTR. It makes "sense" or TH to tax unremitted income in order to increase inflows to TH. One way could be to reverse the inflow several days later but my guess is that there could be a problem as soon as you start to transfer 6 or 7 digits USD amounts out of Thailand every year. Pls ask TRD if you are currently in Thailand. The current status is that no one knows.

It that so that gifts are legal up to 2000? I would really like to know, krap!

All the aforementioned discussion was under the requirement that a ww income taxation comes into play as stated several times or that cap gains are remitted to TH. Amazing to what length you go instead of simply saying you were not aware on the impact of ww taxation if you have capital gains. Again there is no withholding tax on cap gains in ANY major country that I know of. Sorry to say but apparently you do not understand the working of withholding tax despite the fact it was pointed out several times and you do not understand the difference in taxation between cap gains and interest and dividends. Wrap up: Cap gains are taxed according to PIT i.e. up to 35%. No losses can be offset, in 2024 cap gains that are remitted should be taxable. If ww taxation comes into place all cap gains should be taxable whether remitted or not. So this is a huge difference for asset rich investors. No withholding tax can be substracted from cap gains as cap gains are (usually) not taxed in the country where they arise.

So what do you propose when it comes to handing in the tax declaration? It is either tax evasion (not handing in or understaating) or you state your correct cap gains. You seriously think then that you do not have to pay because you are just a "small" investor? Where is that stated in the thai tax code? You simply have to pay according to your thai tax PIT bracket.

So to put is simply you think one will have to pay or one won't have to pay PIT on capital gains? Do you agree that you were not aware that capital gains were taxed in TH. Why is it so difficult to make a clear statement when one is wrong about something?

Investements in the Thai SET are tax free but that might be 0.01% of the amount that people in this forum have invested, so close to irrelevant. If international taxation comes into play you will have to pay capital gains taxes. Sorry but apparently you were not aware about capital gains taxes in TH and now you claim that they will not apply for individual investors for some mysterious reason that you fail to mention.

Capital gains are taxed like ordinary income in Thailand hence 35% in the highest tax bracket. To make things even worse, losses cannot be offset against gains!