I already have a house in South Pattaya worth around 8 million Baht. My plan, developed during the pandemic, was to sell it, bring in another 6 million Baht or so from my offshore savings, and buy a bigger house, still in Pattaya but away from the mass tourism which has got out of control now. In theory, as the savings were in my account prior to 1/1/24, that would be tax-free, but even this snake oil salesman, Carden, admits that its still a grey area where nobody knows how it will be treated. So now, if the TRD gets aggressive with its tax plans, I'll just go the non-resident route, stay in Thailand for 170 or so days a year in future, and use the 6 million Baht to buy another house, probably in the Philippines, and stay there for around 130 days a year, so also not tax resident. The remaining 60 or so days a year I already spend in my property back in the UK, so buying one more in the PI isn't a hardship.
Governments need to get realistic about this, the idiots in the OECD may rant on about tax justice but to be fair it needs to be a double-edged sword. If a country wants someone to pay tax like a local then they should also offer them similar benefits to a local; the right to own land, for example, and a fast-track route to permanent residency, then maybe people like myself would be more willing to pay tax. As things stand, if global income is really to be taxed wherever you are living on the planet, then I might as well become tax resident in the UK again, at least I'd qualify for NHS treatment and prescriptions, and my state pension would be indexed.