Eudaimonia

Foreign-sourced dividends are taxed progressively using the same personal income tax rates as salary. A salary is probably not foreign-sourced income, unless the wife travels abroad monthly to perform her duties. If she stays in Thailand and draws a monthly salary, it has been local, taxable, reportable income even before 2024.

Great initiative. "Note that if you are generating income by working while staying in Thailand, it is (and has always been) irrelevant where that money is paid and whether you bring the money into the country or keep it offshore."

Yes, it should be "after Jan 1, 2024."

Even before September 2023 and the current debacle, the best Thai tax experts advised that even the ubiquitous interpretation of a previous year's offshore income being tax-free has no actual and clear base in law. That may not have been something widely discussed, but HNWIs were advised that they need to be careful with their remittances and filings. Check out this quote: "In my view the new interpretation is consistent with what the law has always said," said Jonathan Stuart-Smith, a tax partner at Mazars of Thailand, a tax consultancy. "It’s just that Thailand’s always had a lucky break, and there’s been this narrow interpretation on the table for a long time." https://www.businesstimes.com.sg/international/asean/thailands-tweak-tax-regulation-foreign-income-sparks-confusion-worries Being a tax resident of Thailand has been, and can still be, quite advantageous thanks to many characteristics of Thai tax laws. People with considerable offshore income might end up with a <1% global tax rate even in 2024 if most earnings are kept offshore and not remitted. However, taking advantage of Thai hospitality by being a tax resident necessitates that all taxes are being filed correctly and everything is above board.

I came across a good summary article, especially for Australians. Apologies if it has already been shared here. https://www.expattaxes.com.au/update-thailand-clarifies-tax-on-foreign-income/ The only thing that puzzles me about this article is the mention: "There’s ambiguity over whether foreign-sourced income will attract a specific rate of tax in Thailand or whether it will be subject to Thailand’s ordinary tax rates." I am not aware of any ambiguity, isn't it the same progressive rates as for other incomes? Of course that might change later, but not much time to change it for 2024 now.

Yes. The ambitions are much higher. For global taxation to work, lots of new laws are needed. People who do not want too much taxable income typically set up holding companies and so forth. Of course, the OECD countries provide great examples, so leapfrogging is possible.

To be honest, I think the big money is either moving soon or being taken care of by lawyers and bankers who know how to prove these things later. Grandfathering pre-2024 income was not part of the original Order or plan. It was announced later when they understood how complicated everything would otherwise become. Perhaps some influential people also mentioned that they will need at least one more year to repatriate their funds. If you have the money and want to buy a condo, I would not wait until 2028.

All income earned before 2024. If you want to transfer some in 2040, keep it in a ring-fenced account with no incoming transfers and 0% interest until then. Otherwise, it will indeed become difficult or impossible to show what is from pre-2024.

No worries. You can file in January as well. Of course, if you did not stay 180+ days in Thailand in 2023, you're not even a tax resident, so you do not need to file anything. Overall, it looks like it's just me and maybe ten other foreigners in the country who have bothered to hire tax lawyers and auditors to structure their affairs and follow tax laws here and in every other country we have interests in. For 99% of expats in Thailand, it seems to be a big surprise that their foreign source income and remittances may have been taxable all along because they did not even follow the current rule and wait until the next calendar year to remit it. I would not expect the Revenue Department to start investigating old remittances, but they do have the 2023 CRS data, so who knows.

It's your 2023 offshore rental income, so you can remit now and file a tax return in March showing it as assessable 2023 income remitted in the same year it was earned. Or you can wait until January and get it tax free.

There is a useful futures contract trading on the Singapore Exchange – SGXTU, or Thai Baht in US Dollar Futures. I've used it to hedge my January 2024 transfers, in case people start remitting a lot.

No capital gains tax for the sale of US stocks. 15% withholding tax on dividends for Thailand tax residents. Portfolio interest (debt instruments like bonds and some preferred stocks) is tax-free.

Again, if you had income in 2023 and remit that money now (in the same tax year), it's taxable. If you send it on 1 January 2024, it will not be taxable. (You can send it later as well, but then it might be more difficult to prove it is pre-2024 income.) All new earnings from 1 January 2024 onwards will be taxable regardless of when remitted.

If you had income in 2023 and remit that money now (in the same tax year), it's taxable. If you send on 1 January 2024, it will not be taxable. The choice seems pretty obvious.

The point is this: Your calculation shows an 8 million deposit in Bangkok Bank, which is then spent gradually. The last 500,000 in savings, to be used in early 2028, will have enjoyed over four years of holiday in Bangkok Bank. If kept offshore and invested, this money could (in my humble opinion) have been working offshore and earning much more during that time. I think your principle makes a lot of sense. I will also bring in a lump sum of tax-free money on 1.1.2024 and then remit something taxable every year in the future. However, it is rather difficult to optimize the ratio. Small tax savings seem to lead to big lost profits. By the way, I don't think a 6-8% yield is unrealistic. Even US Treasuries that I bought recently have a yield on cost of over 5% until 2040. The average annualized return of the S&P 500 since 1928 is 9.81%.