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Anyway only the gain or income part is taxable on the withdrawal. So if you transfer 200K USD from a loss making trade the tax rate is supposedly zero if TRD accepts your paper work. Same for funds from before 2024 etc or income that has already been taxed.

This is very interesting and thanks for posting it! Could you elaborate if the accounting method they used was mandatory or up to debate? Usually there is no withholding tax on interest on an offshore account or for that matter not even Germany has a witholding tax on interest, so how come you paid wht? Again much obliged because the whole thing will be about the accounting method at least for the majority of people. Why was there an audit in the first please if you do not mind me asking.

Uk dividends come without a withholding tax, one of the few countries without WHT like Singapore, Ireland and some Aussie shares.

I am not allowed to post sources in German here that confirm my statement, sorry.

Just try to make sure you do not remit the German gov. pension to TH. Best keep the pension aside in a different account if possible. So as long as they do not change to ww taxation you should be tax free. I do not know anything about the other pensions you mentioned, sorry.

TH has currently the right to tax the gov. pension and I assume they will IF you remit to TH. Are you getting gov. pension or company pension? The German IRS will sometimes try to tax all pensions but when you write to the German IRS in Neubrandenburg that deals with all expats they will relent in the end. That was the consensus of several German expats I dealt with. Do only contact German IRS if they already tax you 😉

German gov. pensions are not taxed in Germany and are supposed to be taxed in TH, but TH never used its right up to now. I know numerous people that have not been taxed neither in GER nor in TH in the past. Anyway the German gov. penion was/is paid to a high percentage out of already taxed income (was changed in 2005) so basically you are getting back the money you have paid 30 years ago.

For example the German government pension is taxable and asseable in Thailand according to DTA, so IMHO a lot of people are over 560K per year, maybe not in the case of us or uk penions agreed. There was a respectable German YT who reported that no taxes will be levied for holders of the Elite Visa.

This is also the way I understand it. Reminds me of the power of discretion of the IO officer that could deny entry even if you had a perfectly valid visa. If the wording is applied correctly one should always get the exemption as long as one has enough income 80K USD per year so SHOULD be fine I hope.

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.