Legal Strategies to Reduce Thai Tax

[Startmeup]

On 5/21/2024 at 8:19 AM, Presnock said:

Well, I am not so sure, I still see some asking particular questions about documentation for qualifications, plus clarity in this new interpretation of the tax laws and how they might or might now affect one's quality of living due to taxation or problems associated with the interpretations of the TRD, some might just decide then so that they don't have to think about it for an extended period of time, they might

go ahead and apply for the LTR.  I only go mine a couple of months ago (MARCH) as I have not had any realproblems with my retirement O for 20 years and even with the new tax bit, I only have a US govt pension so felt pretty confident that the DTA would mean no effects from the new interpretation but then looked closely at the BOI LTR and realized it fit me better than any other visa.  Glad I changed.  Happy to stay another 10 years and hopefully worry free as TIT and one never knows...just like this Thursday we might see some unhappy people.

Let's think about this rationally. There are alot of different circumstances but anyway….


 "The personal remittances received in Thailand declined to 8.92 billion U.S. dollars in 2022. Nevertheless, the last two years recorded significant higher personal remittances received than the preceding years.
A remittance is a non-commercial transfer of money by a nonresident worker, a member of a diaspora community, or a citizen with familial ties abroad, for household income in their home country. Workers’ remittances are a significant part of international capital flows, especially regarding labor-exporting countries."

So roughly $9B coming into the country that needs to be tracked under these new rules. Excluding use of credit cards and maybe ATMs? There is said to be 300k expats living in Thailand
 

Let's be generous and say they average $100k p.a brought into Thailand. Thats $3B. So that leaves another $6B from Thai/Foreigner abroad sent to Thais in need of money.

I can say with a high degree of certainty the bulk of this would be to people who don't even file a tax return let alone go out of their way to declare money from abroad. How many employed Thais file a tax return anyway, none that I know of I suspect the company deducts tax from the pay and declare a small portion of it and even that likely doesn't happen much. 

The only way this will be enforced is through people voluntarily filing and declaring they remitted money themselves. Filing a tax return would be right at the bottom of things to do for any local living here who are living week/week month/month. Is The government going to go after all of them, they will be waiting a while to see any of it. 

 

So the RD will be hoping that the potential changes of rules will lead to self enforcement or they will target a select group of people who qualify in the new rules, maybe. Maybe they will target foreigners, Pick a few people off to scare everybody into self enforcement. 

Which brings me back to a post I made in another similar thread, send your money to a Thai friends bank account and withdraw it from the ATM. These rules will be unenforceable for the locals. If you're still worried, Bring a toke amount into your own bank account to show something and do the bulk to a friends. 

I wonder how many threads like this are being started in Thai forums panicking about these new rules, lol, zero. 


 

[Mike Lister]

43 minutes ago, J Branche said:

Also Reference Thailand Revenue Department Order

 

No. P.162/2023 issued 21 November 2023

“The provisions of paragraph one Section 41 shall not apply to assessable income arising before the date 1 January 2024.”

NOT TAX ADVICE, I interpret this as keep Clear, Documentation of Source (Pension, Social Security, Wages, Investment), Proof that this was assessable before 1 Janurary 2024 and the Balance showing the amount assessable Before and After 1 Jan 2024 so there will be little confusion.  No unjustified taxes.

 

Also reference YouTube Channel

Expat Tax Thailand  I believe he answers a lot of the common questions 

 

Additional Be Aware that the Same Deductions and Exemptions are allowed and applied to Foreign Sourced Income Remitted to Thailand

unless otherwise specified.  Single Person 60,000 baht deduction, actual policy cost not more than 25,000 Baht for Health/Medical Insurance Policy from THAI Business.  I have Pacific Cross or (Pacific Cross Health Insurance PCL) office Bangkok since they are licensed, registered and have office in Thailand they should qualify.  Wages receive a deduction, Check on percentage.  After all these the first 150,000 baht Remitted is 0 Zero tax.

So effectively the first 210,000 Baht is remitted 0 Zero Tax. 

 

I suggest you read the following:

 

 

 

[Mike Teavee]

41 minutes ago, J Branche said:

Also Reference Thailand Revenue Department Order

 

No. P.162/2023 issued 21 November 2023

“The provisions of paragraph one Section 41 shall not apply to assessable income arising before the date 1 January 2024.”

NOT TAX ADVICE, I interpret this as keep Clear, Documentation of Source (Pension, Social Security, Wages, Investment), Proof that this was assessable before 1 Janurary 2024 and the Balance showing the amount assessable Before and After 1 Jan 2024 so there will be little confusion.  No unjustified taxes.

 

Also reference YouTube Channel

Expat Tax Thailand  I believe he answers a lot of the common questions 

 

Additional Be Aware that the Same Deductions and Exemptions are allowed and applied to Foreign Sourced Income Remitted to Thailand

unless otherwise specified.  Single Person 60,000 baht deduction, actual policy cost not more than 25,000 Baht for Health/Medical Insurance Policy from THAI Business.  I have Pacific Cross or (Pacific Cross Health Insurance PCL) office Bangkok since they are licensed, registered and have office in Thailand they should qualify.  Wages receive a deduction, Check on percentage.  After all these the first 150,000 baht Remitted is 0 Zero tax.

So effectively the first 210,000 Baht is remitted 0 Zero Tax. 

 

235,000 for you (as you have the 25,000 allowance for your Pacific Cross Health Insurance Policy), I'm in exactly the same position. 

[Mike Teavee]

27 minutes ago, dinga said:

Don't you just need to have documentation to show the closing balance of all offshore investments as at 31/12/2023??? ie.  aren't all such balances not-accessable.  Agree all investments after that date - and which are the source of transfers to Thailand by tax residents - will need detailed evidence/documentation to support whether assessable or not-assessable

 

Or am I missing something here?

From the ExpatTax videos I've seen, Thailand isn't allowing you to use an asset's value as at 31/12/2023 as the basis from which to calculate Capital Gains, you need to use the original cost. 

 

For Savings yes, whatever balance you had in your savings account as at 31/12/2023 is clear from being assessable income.

[Mike Lister]

2 hours ago, Klonko said:

Therefore, if the spouses' properties are subject to Thai marital law, a "gift" remittance between spouses from foreign income from personal property comes from joint marital property and IMO 50% of such remittance should qualify as regular tax assessable income of the receiving spouse. If the spouses' properties' are fully separated under applicable foreign law, such remittance remains fully tax exempt within Thai gift rules.

I think that answers the questions about conjugal property, visa ve Gift Tax and the reservations I had earlier, I'd completely overlooked/forgotten about Sin Suan Tua.

[Mike Teavee]

3 hours ago, JimGant said:

***Removed by Moderator***

 

[Mike, this is not a recommendation to do something illegal -- since there is no legal guidance out there defining tax exemptions on gifts. Thus, in the absence of any guidance, why not advise the readers of their options to give themselves the best deal on a grey area. Yes, when, or if, something more definitive in law comes along, then, you can remedy the guidance on this forum to conform to the latest law.]

 

By snipping my post you've completely misrepresented what it said, I was answering the question around whether Gifts are conjugal property, there was no mention of the (what I thought was parked) argument about whether the Gifter needs to declare the Gift assessable income. 

 

[JimGant]

3 minutes ago, Mike Teavee said:

By snipping my post you've completely misrepresented what it said

My apologies. I didn't read deeply what you said, but I guess it had to do with applicability to gift taxes, since you've put to rest the notion that remittances that become gifts somehow have an exemption from income tax. Thank you for shutting that door.

[Mike Teavee]

Just now, JimGant said:

My apologies. I didn't read deeply what you said, but I guess it had to do with applicability to gift taxes, since you've put to rest the notion that remittances that become gifts somehow have an exemption from income tax. Thank you for shutting that door.

I've done no such thing as I still believe Gifts remitted into Thailand are exempt from Income Tax but we all agreed that we were not going to agreed to park it pending "Official" confirmation one way or another. 

 

As it's been brought up again, I will just state my argument for why I believe this & people can believe what they want until it's proven one way or another. 

1. The Thaksin Wife case shows that at that time there was scope for remitting Gifts tax free into Thailand with no limit on the amount that could be gifted, there was no income tax due on the Gifter at that time.  
2. The law was changed in 2016 to add the 20/10 Million limits, add a 5% Gift Tax for gifts over that value & put some criteria about what is & what isn't a gift, to the best of my knowledge there was no change to the fact that the Gifts could be remitted free from Income Tax  

I hear the argument about it being a big loophole that people can exploit but that's why limits were included & if anything I expect TRD will reduce these over time rather than abolish them all together.

 

That's me out... (Literally, the GF is nagging me to go shopping)...

[Yumthai]

https://www.rd.go.th/43338-1/clear-cut-ภาษีการรับให้-gift-tax-ใครต้องเสียภาษี.html

 

This is a 2023 Q&A in Thai from TRD related to Gift Tax.

 

What we learn among other things (Google Translate):

- Receiving tax Or commonly called Gift Tax, is a personal income tax collected from assets given or received to children, spouses, relatives, or other persons before the gifter's death. The gift tax was created to be consistent with the inheritance tax, preventing inheritance tax evasion.

- The giftee is the sole responsible of the income/gift tax payment. No mention of the gifter.

- Parents mean father, mother, grandparents, great-grandparents.

- Descendants mean children (including adopted children/illegitimate children certified by the father), grandchildren, great-grandchildren.

 

[Lorry]

3 hours ago, bamnutsak said:

 

Can you share any details on how you buy SOTI? In which country do you purchase "most of your tickets"? Maybe a sample itinerary, airline and pricing. How do you choose the currency?

 

AFAIK, International Sales Indicators (ISI) were modified 15 January 2005.

 

Since 2005 I have bought tickets originating in Bangkok in 2 ways.

I was physically sometimes in Thailand,  sometimes not.

 

1. I bought myself from the airline that operates the flight, using their website or their ticket counter. 

Various European and Asian airlines 

Price -billing and payment - was always in THB.

 

2. I bought through an intermediary (a travel agent or an airline which didn't operate the flight) not based in Thailand. 

Flight was with various Arab, European and Asian airlines, including TG.

Price - billing and payment - was never in THB, it was USD (if the intermediary was American) or EUR (usually if the intermediary was European). Payment was never in Thailand. 

 

I never chose the currency,  I payed whatever they wanted. 

 

[treetops]

54 minutes ago, Lorry said:

1. I bought myself from the airline that operates the flight, using their website or their ticket counter. 

Various European and Asian airlines 

Price -billing and payment - was always in THB.

 

Similar, but not quite the same for me.

 

Air France recently directed me to their Thai site to purchase tickets based on my origin/location being Thailand. At the end of the process they tried to hit me with a credit card (maybe as much as 800 THB IIRC) so I changed site to the UK version.  Purchased the same tickets as I had originally planned but was charged in GBP with no credit card fee and the mark up for them doing any conversion behind the scenes was about 10% of the 800 THB fee they would have charged.

 

I don't know the intricacies of airline ticketing but that seems to me like SOTI.

[Mike Lister]

3 hours ago, JimGant said:

***Suggesting ways to evade Thai tax, removed by moderator ***

 

[Mike, this is not a recommendation to do something illegal -- since there is no legal guidance out there defining tax exemptions on gifts. Thus, in the absence of any guidance, why not advise the readers of their options to give themselves the best deal on a grey area. Yes, when, or if, something more definitive in law comes along, then, you can remedy the guidance on this forum to conform to the latest law.]

How about we don't do that, as we have said previously that we wont, in similar scenarios, we DONT offer advice or advise best scenarios, end of.

 

Suggesting a way to evade tax and then saying you are not suggesting a way to evade tax, doesn't get you off the hook.

 

That's strike number two in this thread....for the benefit of those with short memories and short attention spans, let me post what I wrote at the outset, for the third and last time.

 

"If everyone promises to behave and not cross the line or play word games, we can discuss ways to legally mitigate/reduce/avoid tax. If however the discussions start to go in the wrong direction, not even a portable defibrillator will save it. It is therefore in members best interests to ensure no lines are crossed and ensure the debate is self managed". 

 

 

[JimGant]

6 minutes ago, Mike Lister said:

How about we don't do that, as we have said previously that we wont, in similar scenarios, we DONT offer advice or advise best scenarios, end of.

Nonsensical. We're completely adrift on how to handle foreign remitted income -- in many situations, like gifts -- because the Thai authorities have not clarified, or even defined, the laws related to such remittances. So, why in the world would a forum that's trying to give options to its readers -- options that DON'T violate any existing law -- be told by its leader to not provide any options?

[Mike Lister]

1 minute ago, JimGant said:

Nonsensical. We're completely adrift on how to handle foreign remitted income -- in many situations, like gifts -- because the Thai authorities have not clarified, or even defined, the laws related to such remittances. So, why in the world would a forum that's trying to give options to its readers -- options that DON'T violate any existing law -- be told by its leader to not provide any options?

Two choices:

 

1) Find/uncover/wait for new relevant information that clarifies what the rules really are, not what you think they are, not what you think they should be.

 

2) Don't discuss it.

 

What is not a choice is advising members not to declare income on their tax return, because it might be this or that or something else that you think. Are we on the same wavelength yet?

[redwood1]

7 hours ago, Startmeup said:

Let's think about this rationally. There are alot of different circumstances but anyway….


 "The personal remittances received in Thailand declined to 8.92 billion U.S. dollars in 2022. Nevertheless, the last two years recorded significant higher personal remittances received than the preceding years.
A remittance is a non-commercial transfer of money by a nonresident worker, a member of a diaspora community, or a citizen with familial ties abroad, for household income in their home country. Workers’ remittances are a significant part of international capital flows, especially regarding labor-exporting countries."

So roughly $9B coming into the country that needs to be tracked under these new rules. Excluding use of credit cards and maybe ATMs? There is said to be 300k expats living in Thailand
 

Let's be generous and say they average $100k p.a brought into Thailand. Thats $3B. So that leaves another $6B from Thai/Foreigner abroad sent to Thais in need of money.

I can say with a high degree of certainty the bulk of this would be to people who don't even file a tax return let alone go out of their way to declare money from abroad. How many employed Thais file a tax return anyway, none that I know of I suspect the company deducts tax from the pay and declare a small portion of it and even that likely doesn't happen much. 

The only way this will be enforced is through people voluntarily filing and declaring they remitted money themselves. Filing a tax return would be right at the bottom of things to do for any local living here who are living week/week month/month. Is The government going to go after all of them, they will be waiting a while to see any of it. 

 

So the RD will be hoping that the potential changes of rules will lead to self enforcement or they will target a select group of people who qualify in the new rules, maybe. Maybe they will target foreigners, Pick a few people off to scare everybody into self enforcement. 

Which brings me back to a post I made in another similar thread, send your money to a Thai friends bank account and withdraw it from the ATM. These rules will be unenforceable for the locals. If you're still worried, Bring a toke amount into your own bank account to show something and do the bulk to a friends. 

I wonder how many threads like this are being started in Thai forums panicking about these new rules, lol, zero. 


 

 

Very good post....So good I wish I had written this.....lol

 

People here need get out of the tax tunnel vision and look at the bigger picture....

[Mike Lister]

A MESSAGE FROM THE MODERATION TEAM - IMPORTANT 

 

Until we have a clear answer from a reliable source about Gift Tax, or any other aspect  of Thai taxation and assessable income, we will avoid providing any form of guidance to members that can potentially get them into trouble later. If this means we aren't able to conclude on some aspects of Thai tax for many months, so be it.

 

This aspect is now being scrutinised closely from several quarters, our position is very clear, providing no guidance is far better than providing bad guidance. This rush to tell members something/anything, that makes sense to just one person alone, must stop now. Just because we don't know what the law/rules are yet, doesn't mean that no rule/law exists. Not knowing what the official line is, isn't grounds to assume there isn't one and that members can make up their own rules and hand them out as advice. I cannot stress sufficiently how important this is, this  is a big deal.

 

From hereon, any post that contravenes the above standards will be removed without further explanation or notice and additional steps taken as necessary. If anyone wishes to discuss this matter, please do so via PM with me or Admin but do not debate it here.

 

Thanks

 

[KhunHeineken]

Has a member ever brought in over the allowed amount of currency, but declared it?  If so, can you comment on what happened? 

[Mike Lister]

1 minute ago, KhunHeineken said:

Has a member ever brought in over the allowed amount of currency, but declared it?  If so, can you comment on what happened? 

What happens is you sign the Customs declaration and retain a copy in case you want to take those funds out again, you have proof they were brought in from overseas. 

[KhunHeineken]

1 minute ago, Mike Lister said:

What happens is you sign the Customs declaration and retain a copy in case you want to take those funds out again, you have proof they were brought in from overseas. 

Really? 

 

So, that's all.  Bring in $1 million USD by signing a piece of paper.  No questions to answer.  No other records kept. 

 

Have you ever done it? 

[Mike Lister]

2 minutes ago, KhunHeineken said:

Really? 

 

So, that's all.  Bring in $1 million USD by signing a piece of paper.  No questions to answer.  No other records kept. 

 

Have you ever done it? 

I've brought in over the limit and declared it, I gave the copy of a customs form to my bank but they weren't really interested in it.

[KhunHeineken]

7 minutes ago, Mike Lister said:

I've brought in over the limit and declared it, I gave the copy of a customs form to my bank but they weren't really interested in it.

I am talking about at the boarder.  What happens?   I don't expect anyone to know what happens behind the scenes.  I am asking what happens at the boarder.  Are you waved through?  Are you pulled aside?  Are you questioned?  Etc etc.

[Mike Lister]

4 hours ago, KhunHeineken said:

I am talking about at the boarder.  What happens?   I don't expect anyone to know what happens behind the scenes.  I am asking what happens at the boarder.  Are you waved through?  Are you pulled aside?  Are you questioned?  Etc etc. 

I already said, I declared it! At the airport I went to the red channel and declared it to Customs, they weren't phased by it.

[Lorry]

1 hour ago, KhunHeineken said:

Has a member ever brought in over the allowed amount of currency, but declared it?  If so, can you comment on what happened? 

Same as Mike.

No fuss at all, but it wasn't a million US.

Home country customs asked for the purpose.  Standard answer "I want to buy a car". Standard reply from customs "Yeah, that's what most say"

(In Thailand using cash is not yet illegal)

[Lorry]

I plan to bring less than the allowed amount, but would like to declare it, to have a paper trail.

I am afraid that will be a problem. 

They certainly will not understand. 

[Mike Lister]

I have updated the document to reflect the Sin Suan Tua aspect:

 

77) Two additional points on this subject are: 1) Funds that are gifted, must be for the use of the person to whom they are gifted. 2) Gifts can be revoked later and reclaimed, under specific circumstances, such as if the receiver of the gift defames the Gifter or fails to take care of their serious medical needs. However, Gifts to a spouse become Sin Suan Tua or the sole property of the spouse, under marital law the gift is not regarded as conjugal property. Until the circumstances surrounding Gift Tax and all it entails, becomes more clear,, it is critical that anyone wishing to use Gift Tax, seeks professional advice.

[Mike Teavee]

23 minutes ago, Mike Lister said:

I have updated the document to reflect the Sin Suan Tua aspect:

 

77) Two additional points on this subject are: 1) Funds that are gifted, must be for the use of the person to whom they are gifted. 2) Gifts can be revoked later and reclaimed, under specific circumstances, such as if the receiver of the gift defames the Gifter or fails to take care of their serious medical needs. However, Gifts to a spouse become Sin Suan Tua or the sole property of the spouse, under marital law the gift is not regarded as conjugal property. Until the circumstances surrounding Gift Tax and all it entails, becomes more clear,, it is critical that anyone wishing to use Gift Tax, seeks professional advice.

 

I think one thing we can all agree on is a Gift would be free of Thai Income Tax for both the person giving & receiving the Gift if:-

1. The Gift is made outside of Thailand (E.g. I gift my Wife £500K in the UK).
2. The Gift is documented as a Gift (The more formal the documentation the better).
3. The Wife remits a maximum of 20Million THB in any one year or she pays 5% Gift Tax on everything over this, In the example of £500K she could choose to leave approx. £65K / 3 Million THB in the UK & remit it next year, or she can pay approx. 150K THB Gift Tax)

 

I don't know about other countries, but nowadays, it's hard enough for UK Expats to open a UK Bank account for themselves never mind a non-UK Citizen who doesn't live there, but people who are planning the move might be able to arrange to set up accounts before they become fulltime Thai Expats. 

[Mike Lister]

4 minutes ago, Mike Teavee said:

 

I think one thing we can all agree on is a Gift would be free of Thai Income Tax for both the person giving & receiving the Gift if:-

1. The Gift is made outside of Thailand (E.g. I gift my Wife £500K in the UK).
2. The Gift is documented as a Gift (The more formal the documentation the better).
3. The Wife remits a maximum of 20Million THB in anyone year or she pays 5% Gift Tax on everything over this, In the example of £500K she could choose to leave approx. £65K / 3 Million THB in the UK & remit it next year, or she can pay approx. 150K THB Gift Tax)

 

Nowadays, it's hard enough for (UK) Expats to open a (UK) Bank account for ourselves never mind a non-UK Citizen who doesn't live there, but people who are planning the move might be able to arrange to set accounts up before they become fulltime Thai Expats. 

Agreed. I'll add parts of that to the notes.

[Mike Lister]

A further update to the Gift tax para 76/77

 

76) Additional points on this subject are:

 

a) Funds that are gifted, must be for the use of the person to whom they are gifted.

 

b) Gifts can be revoked later and reclaimed, under specific circumstances, such as if the receiver of the gift defames the Gifter or fails to take care of their serious medical needs.

 

c) Gifts to a spouse become Sin Suan Tua or the sole property of the spouse, under marital law the gift is not regarded as conjugal property.

 

d) Gifts made outside Thailand appear to be safe.

 

e) The Gift must be formally documented and recorded, the more documentation the better.

 

f) No more than THB 20 mill should be remitted to Thailand per year, unless 5% Gift Tax is paid on the balance.

 

77) Until the circumstances surrounding Gift Tax and all it entails, becomes more clear,, it is critical that anyone wishing to use Gift Tax, seeks professional advice.Note: Because Gift Tax is predominantly a domain of the wealthy and depends to a large extent on local practice, there is a shortage of confirmed information on this subject. One field of thought is that Gift Tax cannot be used to escape Thai tax by Gifting untaxed money from overseas. On the other hand, many Western countries, including the UK, do not tax gifts from overseas. Members wishing to exercise this option should seek qualified advice before using this option to Gift untaxed funds.

[Klonko]

5 hours ago, Mike Lister said:

A further update to the Gift tax para 76/77

…

d) Gifts made outside Thailand appear to be safe.

 …

f) No more than THB 20 mill should be remitted to Thailand per year, unless 5% Gift Tax is paid on the balance.

…

Gifts made outside of Thailand and remitted to Thailand up to THB 10/20m by the receiver are not safe per se. If the gift comes from conjugal property such as income from personal property under Thai marital status, IMO 50% of the remittance are tax assessable income of the receiver.

 

I have set up a gift scheme for myself, but I will watch closely and decide before year end if my scheme is still viable. If viable, I will remit tax assessable income to my account resulting in a tax netted by the withholding tax on my Thai bank accounts. If not viable, the income tax on the "gifts" will also be netted by the withholding tax. I deliberately forego a refund of the withholding tax. To file or not to file is an open issue. My gift scheme gives me 50% more years I can live off savings before I have to use the 179 day rule.

 

If gifts are used without the required assertions from TRD, I recommend being prepared for taxability as plan B. Hopefully, more TRD guidance will be available before year end.

 

Re f): THB 10/20 mill

[Mike Teavee]

1 hour ago, Klonko said:

Gifts made outside of Thailand and remitted to Thailand up to THB 10/20m by the receiver are not safe per se. If the gift comes from conjugal property such as income from personal property under Thai marital status, IMO 50% of the remittance are tax assessable income of the receiver.

 

I have set up a gift scheme for myself, but I will watch closely and decide before year end if my scheme is still viable. If viable, I will remit tax assessable income to my account resulting in a tax netted by the withholding tax on my Thai bank accounts. If not viable, the income tax on the "gifts" will also be netted by the withholding tax. I deliberately forego a refund of the withholding tax. To file or not to file is an open issue. My gift scheme gives me 50% more years I can live off savings before I have to use the 179 day rule.

 

If gifts are used without the required assertions from TRD, I recommend being prepared for taxability as plan B. Hopefully, more TRD guidance will be available before year end.

 

Re f): THB 10/20 mill

I think you might be mixing things up a little, you can't gift something to somebody that they already own so in the case of overseas conjugal property you can only gift your half. 

 

E.g. I have £100K in a jointly owned bank account with my Wife, I can't gift her £100K as £50K is already hers so I would Gift her £50K which she could then remit into Thailand tax free.

 

If she chooses to remit £100K then she is remitting the £50K Gift that I gave her (Tax Free) & £50K which has nothing to do with Gifts so would be subject to normal assessable income rules, but again, that is nothing to do with Gifts as that £50K wasn't a gift.