chiang mai

Worldwide income, or any derivative thereof, is only in the discussion stages. It will take time for that to be agreed and even longer to be implemented since it requires an act of parliament. expect a few years, if at all.

Nope, there is no new law. only a reinterpretation of an existing rule and it is active now, there is no need for any further enactment, it has been in force since 1 January this year.

"Income from 2025-2028 while non-resident, for example, doesn't become exempt from assessability if remitted in 2029 while tax resident". If you are not resident for tax purposes, your income (earned outside of Thailand) is not assessable in Thailand, for those years, regardless of when it is remitted.

I think you have misunderstood.

Both you or I only need Thailand to adopt taxation scope similar to the UK and as far as we are both concerned, that will constitute worldwide income, for us. My understanding is that Thailand is more interested in adopting the UK model, rather than the US model. That means we will both have to adopt the UK or Thailand for tax residency, which in turn means that all of our income will be taxable, somewhere.

You are not UK resident for tax purposes, which as we both know is the reason why!

It was unclear from what you wrote previously that you were referring to non-assessable funds. If the funds are not assessable, they can be remitted at will, there's no need to remit lots of them now..

The source of the funds and the country they are remitted from, are two different things. Remitting assessable funds from a second country, doesn't make them not assessable. But you get an A+ for creativity and mental effort on that one. 🙂

The above brings us back to my original point, how long must funds be held before they are considered to be something else, savings or just funds...call them what you will. Funds from various sources that are commingled in a single account, lose their identity in many tax regimes and we have yet to understand how TRD handles such accounts. My strongest suspicion is that there is something similar to a statute of limitations governing the origin and status of funds, which if held beyond that period, then causes those funds to enter a different realm of forensics which is not deemed practical or worthwhile investigating, thus an amnesty is given on them. This is mostly conjecture of course but it is based on prior hands on experience.

I was considering other options of alternate use of the funds, after the gain is realised but before they are remitted, preferably something that negates assessability altogether, such as Gifting perhaps, or something in a fixed low rate of tax. The implications of what has been said so far is that the Thai CG aspect must be satisfied at some point and that it can never go away. I don't believe that is necessarily true, the TRD doesn't keep historical records of the status of funds to ensure that each potential liability is satisfied. If the remitter changes the use of those funds, similar to the things you have set out, that is the remiters overseas prerogative which has nothing to do with TRD. It's only the most recent status of the funds that's important, not what they may have been used for years before.

The detailed rules may not yet have been decided but the basic premise of world wide taxation is that all income is declared in the year it arises, regardless of where it arises. If income arises in a year when it is not reported, that would appear to be evasion.

I must admit it does seem that way. Is anyone recording these points that are uncovered or decided, they appear to be important for everyone to know, is there a mechanism for that?

Remitting a lot this year would expose you to more tax, why do it?

We like Kundala but not cheap.

Well no, because under world wide tax rules, the income should have already been reported, if they weren't, that's tax evasion.

Isn't this what Por 162 makes clear?

I disagree that the proceeds of the sale will always remain a capital gain, fifty years hence they will be regarded as savings and the capital gain aspect will be long forgotten. We can however agree to disagree on this point. Not to be pedantic, the concept of worldwide taxation regards events on an annual basis. Once a year has ended, everything that remains is savings and only new events that occur thereafter can be considered for tax. I can assure you that what I wrote in this respect is absolutely correct..

After hearing this news I expect the whole notion of taxing foreigners to be cancelled by lunch time.

I think if I was the Revenue, I might look at that persons bank account to see what withdrawals they were making to live on. When I didn't find any, I might wonder if they were working illegally or involved in illegal activities, that's when the problems start. Confess to tax evasion or admit to cooking and selling crystal meth, a tough call to make.

That was always the plan, from the very outset, even in the US in the 1970's. Reduce branch and staffing costs and monetise the ATM's.

My experience is that outside of places such as Pattaya, most people seem to want to avoid other expats. I think you need to pick and chose very carefully since many here seem to be, er, problematic.

I had to read and re-read your post several times before understanding your point, it's great that you take so much care to address each statement but it can make trying to understand whether you agree with the key point, confusing. I wrote that I was unsure at what point the sale of a capital item such as property, allowed the proceeds to become savings. I didn't say so explicitly but I assumed everyone understood that CG tax would have been paid in the home country where necessary (many expats who rent out their homes must pay CG). At that point, the home has been sold, taxes paid and the money is in the bank, the question is now, are those funds savings, from day one. But then you wrote, "as far as the DTC is concerned they always remain capital gains until remitted to Thailand". I do understand that it is the remitters responsibility to determine the assessability of those funds and to declare them accordingly. This is the entire issue is it not, what exactly is the assessability of those funds? According to your statement, they are always CG gains, whereas I think they become savings at some point in time but do not understand exactly when. IF this were worldwide taxation, those funds would automatically become savings in the following year after they were earned, but it is not....yet!

Beyond shameful.

I was an owner at Floral for several years, the management is excellent, the mosque is not an issue. Easy walking distance to eateries etc, good parking, no negatives really from my perspective, I wish I still had the unit (16th floor). Oh yes, the construction was by a Japanese firm and is built to earthquake resistance standards, there's no cracking despite some serious tremors over the years. Good back up power on site also.

That's not true, it's equally as relevant, the existence of a DTA doesn't negate tax, it merely restructures who the tax is paid to and at what rate