This leads to interesting questions. Let's say you have 100 abroad which is 70 savings and 30 income. You missed the 2 year deadline. So you now put it into the stock market and sell it at 110. If you now transfer the 110 to Thailand immediately, i.e. within 2 years of earning it, what happens? It is all tax free because within 2 years, only the 10 are tax free because only these were gained in the last two years, it is 10+70 (old savings) because old savings are never taxed, but seen as capital, or what is it? And of course excluding gifts and inheritance all savings are really former income of some previous time anyway.