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Clever but Sloppy Tax Changes


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1 Living permanently in Thailand and receive and remit a pension

2 For the 2024 Thai tax year, I will become a tax resident here at midnight 28 June

3 Prior to that time I am a not a Thai tax resident

4 So pension receipts remitted to Thailand before that time are not assessable income here

5 Such remittances after 28 June are assessable income

6 Allowances of 60 + 190 + 100 = 350,000THB are available for this tax year

7 There is no mention of those allowances being pro-rata for part of the year, so all available

8 The full allowances exceed my expected full aged pension 29 June to 31 December

9 So no Thai tax is payable for 2024

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My Double Tax Agreement says:-

“…... pensions and annuities paid to a resident of one of the Contracting States shall be taxable only in that State.”

And I read “resident ……” as “Thai tax resident”

- - - - - - - - - - - - - -

Offered in good faith and hope it will be helpful to many

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5 hours ago, chai333 said:

1 Living permanently in Thailand and receive and remit a pension

2 For the 2024 Thai tax year, I will become a tax resident here at midnight 28 June

3 Prior to that time I am a not a Thai tax resident

4 So pension receipts remitted to Thailand before that time are not assessable income here

5 Such remittances after 28 June are assessable income

6 Allowances of 60 + 190 + 100 = 350,000THB are available for this tax year

7 There is no mention of those allowances being pro-rata for part of the year, so all available

8 The full allowances exceed my expected full aged pension 29 June to 31 December

9 So no Thai tax is payable for 2024

- - - - - - - - - - - - - -

My Double Tax Agreement says:-

“…... pensions and annuities paid to a resident of one of the Contracting States shall be taxable only in that State.”

And I read “resident ……” as “Thai tax resident”

- - - - - - - - - - - - - -

Offered in good faith and hope it will be helpful to many


Please have a look at this thread, for some facts.

 

 

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7 hours ago, chai333 said:

1 Living permanently in Thailand and receive and remit a pension

2 For the 2024 Thai tax year, I will become a tax resident here at midnight 28 June

3 Prior to that time I am a not a Thai tax resident

4 So pension receipts remitted to Thailand before that time are not assessable income here

5 Such remittances after 28 June are assessable income

6 Allowances of 60 + 190 + 100 = 350,000THB are available for this tax year

7 There is no mention of those allowances being pro-rata for part of the year, so all available

8 The full allowances exceed my expected full aged pension 29 June to 31 December

9 So no Thai tax is payable for 2024

- - - - - - - - - - - - - -

My Double Tax Agreement says:-

“…... pensions and annuities paid to a resident of one of the Contracting States shall be taxable only in that State.”

And I read “resident ……” as “Thai tax resident”

- - - - - - - - - - - - - -

Offered in good faith and hope it will be helpful to many

AMAZING, reader obviously went to school as it seems many have not.  The real reply is that until the final revenue department says the final version, most of us can just make our opinion known and in many cases just continue to confuse folks.  Some of the DTA are really in ambiguous terms - a way for politicians and lawyers to be able to interpret meanings of same to be different.  The US DTA says government social security is exempt Article 20 and US government pension exempt Article 21 unless the receipient is a Thai citizen and resident in Thailand.  Seems to be very clear but TIT.

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