Been there done that mate - know a lot about it (from another life) - know Canberra and the APS well. There is one big difference in the Aust/Thai DTA and most others. This is from the Aust/Thai DTA - ARTICLE 18 PENSIONS AND ANNUITIES 1. Subject to the provisions of Article 19, pensions and annuities paid to a resident of one of the Contracting States shall be taxable only in that State. (meaning wherever the person is a Tax Resident). Article 19 excludes Pensions paid to former Government Employees only. That is deliberate I found out, because Aust wants all Pensioners staying in Aust - hence the reason you must actually live there to apply and wait 2 years before moving overseas. That is very unlike most other country's DTAs where the following or something like it is written. ARTICLE 18 PENSIONS 1. Subject to the provisions of paragraph 2 of Article 19, pensions and other similar remuneration paid to a resident of a Contracting State in consideration of past employment shall be taxable only in that State. 2. Notwithstanding the provisions of paragraph 1, pensions paid and other similar payments made under a public scheme which is part of the social security system of a Contracting State shall be taxable only in that State. I am not saying it is definitely going to happen - I am only stating the current situation. But as things stand now it is likely and a potential big problem. But I can guarantee that both Philippines and Malaysia (and Singapore and many others) specifically exclude money earned overseas by their tax residents if it is subjected to the tax system of that country. When this all blew up in 2024 Thailand TRD did not agree to that 'variation' and in fact the Head of TRD at the time said "Foreigners must pay their fair share of income taxes'. Who knows - dont run away for that one reason - but IMO make a plan and run if it is implemented.
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