Puccini

I agree with that. Pay no heed to quotations of obsolete text excerpts from obsolete versions of the Revenue Code. The most updated English translation of the Revenue Code I could find is this version I downloaded from krisdica.go.th with citation of all amendments: https://drive.google.com/file/d/1zR9uui8btXvlMNlfbba4r4Y4Uc2hgQWX/view?usp=drive_link Pay no heed to misquotations or faulty translations of the Revenue Department Order 161/2566. The original Thai text is here: https://drive.google.com/file/d/1EM9zzhFWVS8YNPamaMkl1_jKClbYE3Sz/view The English translation I use is here: https://drive.google.com/file/d/1MDPzd98gSCP5qFu8adZvqCW65qWDC8Dj/view?usp=drive_link

This not true. From the Revenue Department Order: This means that if based on the Double Taxation Agreement the foreign-earned income is not assessible in Thailand, the foreigner must not declare it in his tax declaration to the Thai Revenue Department.

There is now new amendment to the Revenue Code coming into effect on January 1, 2024 What comes into effect on 1 January 2024 is the Revenue Department Order 161/2566, which is, as its first paragraph says , "for revenue officers to use as a guideline in inspecting and advising persons residing in Thailand who have assessable income under Section 40 of the Revenue Code in the past tax year due to duties or business performed overseas or due to assets located overseas under Section 43 (2) of the Revenue Code" The Revenue Code is not being amended, but an effort it being made to apply its section 40 more correctly in future.

The quoted text of Section 41 in the version of the Revenue Code to which the above link on the website of the Revenue Department leads appears to be outdated, as it does not reflect the amended text of the second paragraph introduced the by the Act Amending the Revenue Code (No. 8), B.E. 2496 (1953), which reads as follows: Source: http://web.krisdika.go.th/data//document/ext810/810212_0001.pdf

Oops. Forgot to double-check the number in the search results.

There was a section 41 already in the original Revenue Code of 1939 and it has been amended once, by the Act Amending the Revenue Code (No. 8), B.E. 2496 (1953) Link: Revenue Code 1939, as amended

This seems to be it: https://www.rd.go.th/2578.html

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Does this mean, for example, that if an Italian tourist on a four-week vacation in Thailand applies to open a saving account at SCB, the bank will ask for a Thai TIN or is it his Italian TIN they want to see?

It is understandable that some people may think that what we call a Double Taxation Agreement is meant to ensure or allow double taxation. However, "Double Taxation Agreement" is shorthand for what, in the example of the DTA with Australia, is officially called "AGREEMENT BETWEEN THE KINGDOM OF THAILAND AND AUSTRALIA FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME"

Ask three tax accountants and you get five different opinions.

Interesting. Are you sure about that?

All money that is not assessable income, ie income that is not assessable in Thailand fot the calculation of income tax. Check the DTA between Thailand and your country for for details about what income is taxable in which country.

I've looked at a few DTAs, because of this topic and others on this subject, Germany, Canada, UK, USA, Italy, and I found them to be very clear. How's it with the DTA of your country?

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It expect the Revenue Department Order 161/2366 to be implemented exactly the way it is written: starting from 1 January 2024, if you are a tax resident in Thailand you must include in your annual Thai tax declaration any part of your foreign-earned income for that year that is assessable income, ie income assessable for the Thai tax calculation. Where a DTA is in place, that DTA says in what country the foreign-earned income is assessable and that's the end of the story. If the DTA says that the income is assessable in your country, you must not include it in your Thai tax declaration, regardless whether you transfer any part or all of it to Thailand at any time.

A lot of countries do that with the Value Added Tax (VAT), in some countries called other names, eg General Sales Tax and similar names.

It is an internal guideline for Revenue Department officials and as such doesn't require publication in the Royal Gazette.

1. Yes 2. No.

1. Not for assessable income earned in countries with which Thailand has a Double Taxation Agreement. For other countries, the existing law remains in place and the new Revenue Department Order merely explains its correct application. 2. No

Not quite. The Revenue Department Order being discussed here is not a law. The order is guideline for Revenue Department officials.

The Revenue Department Order 161/2566 is not a new law. The Revenue Department Order 161/2566 does not declare any other law null and void. The Revenue Department Order 161/2566 is a guideline for officials of the Revenue Department to apply and implement Section 40 of the revenue Code correctly.

On the website of Thailand's Revenue Department, I see that the DTA between Thailand and Germany of 1967 is still valid. https://www.rd.go.th/english/2419.html

Correct. Before jumping to conclusions, everybody should check the Double Taxation Agreement (DTA) between his country and Thailand. (I haven't looked at the DTA between Italy and Thailand yet, but this is not urgent as I am not currently a tax resident in Thailand)

This is what the "AGREEMENT BETWEEN THE KINGDOM OF THAILAND AND THE FEDERAL REPUBLIC OF GERMANY FOR THE AVOIDANCE OF DOUBLE TAXATION WITH RESPECT TO TAXES ON INCOME AND ON CAPITAL", completed on July 10, 1967, says: Source: https://www.aseanbriefing.com/userfiles/resources-pdfs/Thailand/DTA/ASEAN_DTA_Thailand_Germany.pdf It is possible and probable that this old agreement of 1967 has been replaced by a newer agreement but I could not find any newer agreement.