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Posted
2 minutes ago, JimGant said:

Would that be money remitted from a BG's foreign account? Even here, there's a chance it's not income -- if not declared as such, how is TRD going to know, unless they interview everyone that receives money from abroad (which would be absurd, as not cost effective)

 

If BG gets the money from someone else's foreign account,  here it's certainly not prima facie income declarable by her -- unless it's a payment for a current service being rendered, like cutting sender's grass while sender is in the States.

 

Anyway, the recipient of wired money from someone's foreign account, if for some reason called into TRD for a chat, could just say the money was a gift (which would put her in the 10k gift tax situation); or that she's just holding the money for the sender, until he returns to Thailand, 'cause he doesn't have a bank account; etc. Again, she's not in an income situation, unless performing current services. It's the remitter, if a tax resident of Thailand, who's on the hook for any taxes on remitted monies. But, yes -- a BG who received remittances that exceeded an amount the TRD has established as being subject to random compliance audits -- would just be another individual subject to such an audit. In which case, she could just prove she didn't send the money to herself, thus not subject to any tax (except maybe gift tax).

 

 

Except that TRD has no interest in flagging large remittances from abroad. At this time.

 

Which begs the question of how or why they would notice the 50K baht that Bob in the village remits every month.

 

I am bringing up bargirls who receive big money to illustrate the lack of enforcement by TRD.

 

The likely outcome for 2025 is that Bob in the village who never files will be unaffected. Who will impacted by the new tax regulations? Some Swedish guy who is snagged by the police for some financial crime will be audited, and his remittances traced for examination.

 

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Posted
5 hours ago, Yumthai said:

I hope you're being sarcastic, sometimes I'm wondering.

I so admire posters who tell us they understand the inner working of TRD, they know exactly what they do, how they do it, their priorities, who they tax, etc etc. I'm in awe of those skills!!!

 

That's sarcasm.

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Posted
5 hours ago, Danderman123 said:

Except that TRD has no interest in flagging large remittances from abroad. At this time.

 

Which begs the question of how or why they would notice the 50K baht that Bob in the village remits every month.

 

I am bringing up bargirls who receive big money to illustrate the lack of enforcement by TRD.

 

The likely outcome for 2025 is that Bob in the village who never files will be unaffected. Who will impacted by the new tax regulations? Some Swedish guy who is snagged by the police for some financial crime will be audited, and his remittances traced for examination.

 

Why does the TRD have no interest in flagging large remittances from overseas? The recent rule change means that's exactly what they are interested in, Thai's who have been investing money overseas and now must pay tax on  any profit when it is remitted.

 

And if they're not interested in that, what exactly are they are interested in?

 

You keep talking about the lack of TRD enforcement but you have no first hand knowledge that you've shared with us about what the TRD enforces or how, except anecdotal information about some bargirls you know being financed by o/s boyfriends. Your comments are not even remotely credible as fact and your argument is not remotely credible as even guesswork.

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Posted
1 hour ago, chiang mai said:

Why does the TRD have no interest in flagging large remittances from overseas? The recent rule change means that's exactly what they are interested in, Thai's who have been investing money overseas and now must pay tax on  any profit when it is remitted.

 

And if they're not interested in that, what exactly are they are interested in?

 

You keep talking about the lack of TRD enforcement but you have no first hand knowledge that you've shared with us about what the TRD enforces or how, except anecdotal information about some bargirls you know being financed by o/s boyfriends. Your comments are not even remotely credible as fact and your argument is not remotely credible as even guesswork.

 

In the same way, you're guess-working on effective future tax enforcement.

 

A very small % of Thai residents pays tax, that's factual, and it's certainly a consequence of the lack of TRD enforcement don't you think?

 

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Posted
10 minutes ago, Yumthai said:

A very small % of Thai residents pays tax, that's factual, and it's certainly a consequence of the lack of TRD enforcement don't you think?

 

my personal opinion:

many thais who should be paying taxes do not file tax returns, which is correct. however, a large portion of thais have little or nothing to declare. enforcing tax laws against this group would require a significant effort (manpower) from the TRD, which may is not justifiable.

 

in contrast, enforcing the law on foreigners who are tax residents in thailand is much simpler and would generates more revenue per person for the TRD ...

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Posted
33 minutes ago, Yumthai said:

 

In the same way, you're guess-working on effective future tax enforcement.

 

A very small % of Thai residents pays tax, that's factual, and it's certainly a consequence of the lack of TRD enforcement don't you think?

 

You don't need to be a rocket science to understand that TRD accepts they have a tax collection problem, that's why they amended the rules once already and that's why they would like to amend them a second time, to increase the size of the tax net.

 

My "guess work" that TRD is trying to improve future tax collection and enforcement is based on fact, the BP article tells us that tax collection is improving, "Personal income tax revenue tallied 395 billion baht, 10.9% above the target and 7.5% higher than the previous year".

 

What is factual (from the BP article) is that over 30% of the workforce files a tax return, that is not a very small percentage! What is also factual is that the low average annual wage means a couple earning 24k Baht a month don't have to pay tax. It also means people working as self employed can often earn double that amount and still not pay tax, legally. None of those things have to do with the lack of enforcement of TRD, they are everything to do with the socio-economics of the country.

 

Those things said, I accept that the grey or informal economy is equal to half the value of GDP and that almost 50% of the work force is engaged in it. But as we can see by the recent 10% increase in the tax take, TRD is doing something about it and that trend is continuing, made more possible by electronic banking  data collection. So no, it is not just a "very small percentage" who pay tax and no, the low collection rate is not solely "a result of the lack of enforcement". When Thailand was a purely cash economy, it was nigh on impossible to eradicate tax evasion. Now that every transaction is increasingly captured electronically, the task becomes more manageable, which is why rates are improving.

 


https://www.bangkokpost.com/business/general/2799906/tax-refunds-delayed-by-surge-in-fake-submissions.

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Posted
16 minutes ago, motdaeng said:

in contrast, enforcing the law on foreigners who are tax residents in thailand is much simpler and would generates more revenue per person for the TRD ...

In my view the bigger Thai residents crowd paying on average little tax would, if efficiently collected, generate more tax in total than the smaller foreign residents crowd paying on average a higher amount of tax.

It would be indeed easier to enforce tax on foreigners via immigration but it will be highly discriminatory.

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Posted
5 minutes ago, chiang mai said:

You don't need to be a rocket science to understand that TRD accepts they have a tax collection problem, that's why they amended the rules once already and that's why they would like to amend them a second time, to increase the size of the tax net.

 

My "guess work" that TRD is trying to improve future tax collection and enforcement is based on fact, the BP article tells us that tax collection is improving, "Personal income tax revenue tallied 395 billion baht, 10.9% above the target and 7.5% higher than the previous year".

 

What is factual (from the BP article) is that over 30% of the workforce files a tax return, that is not a very small percentage! What is also factual is that the low average annual wage means a couple earning 24k Baht a month don't have to pay tax. It also means people working as self employed can often earn double that amount and still not pay tax, legally. None of those things have to do with the lack of enforcement of TRD, they are everything to do with the socio-economics of the country.

 

Those things said, I accept that the grey or informal economy is equal to half the value of GDP and that almost 50% of the work force is engaged in it. But as we can see by the recent 10% increase in the tax take, TRD is doing something about it and that trend is continuing, made more possible by electronic banking  data collection. So no, it is not just a "very small percentage" who pay tax and no, the low collection rate is not solely "a result of the lack of enforcement". When Thailand was a purely cash economy, it was nigh on impossible to eradicate tax evasion. Now that every transaction is increasingly captured electronically, the task becomes more manageable, which is why rates are improving.

 


https://www.bangkokpost.com/business/general/2799906/tax-refunds-delayed-by-surge-in-fake-submissions.

The fact that the tax revenue has substantially increased only proves that more people voluntarily declare and thus pay more tax, partly because of alarming (for some) TRD announcements. We have no clue if these announcements where followed by concrete, systemic and successful in-field actions being taken nationwide to audit and collect tax money from residents.

Posted (edited)
6 minutes ago, Yumthai said:

The fact that the tax revenue has substantially increased only proves that more people voluntarily declare and thus pay more tax, partly because of alarming (for some) TRD announcements. We have no clue if these announcements where followed by concrete, systemic and successful in-field actions being taken nationwide to audit and collect tax money from residents.

And how exactly does it manage to do that?

 

To add: fiscal year 2023 ended September 2023, long before the TRD started making announcements about the new tax rule.

Edited by chiang mai
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Posted
5 minutes ago, chiang mai said:

And how exactly does it manage to do that?

Some sheep obey because the shepherd just says beware of the wolf, although there is no wolf.

4 minutes ago, motdaeng said:

what announcements? thanks 🙏 

The change in regulation that is the purpose of this thread!

Posted
3 minutes ago, Yumthai said:

Some sheep obey because the shepherd just says beware of the wolf, although there is no wolf.

The change in regulation that is the purpose of this thread!

Those changes and the announcements didn't begin until September 2023, the same month the announcement was made. Just accept that the TRD is actively trying to do their job and increase the size of the tax net and are not just sitting back doing nothing and that Thai's are paying more tax as a result.......unless you want to play the victim of course!

Posted
3 minutes ago, Yumthai said:

The change in regulation that is the purpose of this thread!

 

it seems TRD did a great job,  because of a small tax rule change starting 2024, TRD increased the revenue in 2023 ... never mind ..  :saai:

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Posted
2 minutes ago, chiang mai said:

Just accept that the TRD is actively trying to do their job and increase the size of the tax net and are not just sitting back doing nothing and that Thai's are paying more tax as a result.......unless you want to play the victim of course!

I've never said TRD is doing nothing, they are apparently very good in Marketing as their communication - only - is being fruitful.

Posted
1 minute ago, Yumthai said:

I've never said TRD is doing nothing, they are apparently very good in Marketing as their communication - only - is being fruitful.

I'm including a link to google calendar so you can download it to figure out the dates involved in all of this. Hint: September 2023 comes before October 2023.

 

https://play.google.com/store/apps/details?id=com.google.android.calendar&hl=en&pli=1

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Posted
42 minutes ago, chiang mai said:

To add: fiscal year 2023 ended September 2023, long before the TRD started making announcements about the new tax rule.

 

"In Thailand, the government's fiscal year (FY) is 1 October to 30 September of the following year.[63] For individual taxpayers it is the calendar year, 1 January to 31 December."

 

We're discussing tax on individuals.

 

Sept. 2023 and further announcements had impact on worried individuals feeling the urgent need to start declaring or declare more early 2024 (their 2023 income).

Posted
1 minute ago, Yumthai said:

 

"In Thailand, the government's fiscal year (FY) is 1 October to 30 September of the following year.[63] For individual taxpayers it is the calendar year, 1 January to 31 December."

 

We're discussing tax on individuals.

 

Sept. 2023 and further announcements had impact on worried individuals feeling the urgent need to start declaring or declare more early 2024 (their 2023 income).

One last time, from the article, which reports on fiscal year totals, NOT the tax year:

 

"In fiscal 2023, which ended on Sept 30, 2023, the Revenue Department collected a total of 2.21 trillion baht in taxes, exceeding the target by 9% and surpassing the previous year's figure by 2.1%.

In terms of major tax categories, corporate income tax revenue amounted to 767 billion baht, 13.8% above the target and 5.3% higher than the previous year.

 

Value-added tax revenue totalled 913 billion baht, 5.1% above the target, but 1.8% lower than the previous year.

 

Personal income tax revenue tallied 395 billion baht, 10.9% above the target and 7.5% higher than the previous year, while petroleum income tax revenue was 48.7 billion baht, 25.1% above the target, but 22.4% lower than the previous year".


Please credit and share this article with others using this link: https://www.bangkokpost.com/business/general/2799906/tax-refunds-delayed-by-surge-in-fake-submissions. View our policies at http://goo.gl/9HgTd and http://goo.gl/ou6Ip. © Bangkok Post PCL. All rights reserved.

Posted

Like many others when this was first announced last year I was very worried.  In fact I was over-worried and I did express all that when responding to all those members who said it will never happen and who were going to ignore it. 

 

The truth is taxation laws in any country are very 'punishing' - the biggest part being they can go backwards 7-10 years and demand anyone proves the money they remitted into Thailand was not taxable.  But it aint as bad as I first thought - with a lot of research and planning, I believe that I am OK. Either way, I will be staying away from TRD until this is all sorted out. By that I mean I have calculated that I do not have to lodge a tax return - so I will not - and I will keep all the records just in case.  IMO lodging a tax return in 2025 unless absolutely a must, will only highlight you to the TRD and they will expect more every year going forward. Likewise, you go to a tax adviser and ask 'do I need to lodge a tax return' they will liekly say yes and ask for the money up front (and every year going forward).

 

IMO the vast majority of Expats with only Pensions and Retirement Savings are be excluded, both because most DTAs exclude that type of 'income'.  I also think that Thailand will (eventually) do the same as Malaysia, Indonesia and most other 'retirement countries', and specifically state that they will exclude retired Expat's Pensions and Retirement Savings.

 

Because for decades TRD has ignored the fact that only 10 million of 40 million Thais dont lodge tax returns, and all the Expats who are not working, they do not have the resources, systems or expertise to deal with all the complications that will happen because of this 'order' from the sacked PM to do it. IMO if it does go ahead it will be a total cluster phaarrk and IMO it would be best to stay away from TRD for a few years unless unavoidable.  Those who have been living in Thailand off the earnings they make from overseas investments and earnings from things like property rentals, will have to re-assess staying in Thailand - because you are exactly who they are after in terms of Expats (and all the Thais also doing that).

 

The Thai tax system here is 'self assessment' - and therefore every Expat can assess their own situation. My self assessment is that I do not have to pay any income taxes in Thailand this year.  This is because of a combination of the DTA with the applicable exemptions and allowances, as well as the TRD's own allowances and exemptions for myself and my Thai wife (joint lodgement).  My 'net taxable income' is well below the tax free threshold set by TRD, and based upon advice from a Tax lawyer, I do not have to lodge a tax return if I do not have to pay any income taxes.  The TRD system is setup for those who have income taxes to pay (or already have through work or business), and they are not set up like those in the west where they check and confirm all tax returns, and they chase all those who do not lodge a tax return.   

 

Therefore I will keep my tax records about how I self-assessed things, and if ever asked (unlikely) I will provide those as why I did not lodge a tax return. Plus any money I send to my Thai Wife in Thailand (under 20 million) is not taxable under the TRD gift rule - that is true as long as it goes into her bank account and is spent by her on things like a house, car, shopping, golf, etc etc (and she does not transfer any money to my account). 

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Posted
16 hours ago, NoDisplayName said:

 

Same rules for taxpayers, different rules for registration country of mutual funds. 

 

Mutual funds registered in Thailand = no tax on capital gains.  Mutual funds registered in foreign country = tax on capital gains as ordinary income.

That is an interpretation - not a fact. It could be that, but under the TRD self-assessment system I do not see it that way. If TRD provides an exact detailed response or statement saying that all mutual funds overseas are taxable, then I will accept that as a fact. But until then, what I have read says 'mutual fund'.  A mutual fund is not where a person's money is invested and they are paid interest - a mutual fund is where a group of people, under Government control and rules, invest their already taxed funds for mutual benefit - usually for their retirement savings.  The members of a mutual fund are not paid interest - they mutually benefit from the fund increasing its total value - after the fund has paid to the Government the applicable taxes.  Likewise, they all mutually lose when its value drops like during GFC and/or Covid and/or Ukraine War etc etc.  

Posted
8 hours ago, chiang mai said:

I so admire posters who tell us they understand the inner working of TRD, they know exactly what they do, how they do it, their priorities, who they tax, etc etc. I'm in awe of those skills!!!

 

That's sarcasm.

I admire posters who think anyone else's opinion is stupid and/or wrong.  But I do understand how a bloke living in a small apartment in Pattaya/Patong and who never interacts with Thais other than a BG would have no idea how things work.  If I was in that situation I would listen to those who are married to a Thai, have lived in Thailand for a long time, and who have lost of interactions with Thais people themselves. Especially those whose Thai family and friends is also proving them with their opinions and advice, and who are asking other Thais about this new tax issue - because it directly affects them.   

That is not sarcasm.

Posted
20 minutes ago, TroubleandGrumpy said:

A mutual fund is not where a person's money is invested and they are paid interest - a mutual fund is where a group of people, under Government control and rules, invest their already taxed funds for mutual benefit - usually for their retirement savings. 

 

I think you're mistaken a mutual fund purchased from a bank or brokerage with some sort of IRA.

Posted
28 minutes ago, TroubleandGrumpy said:

Therefore I will keep my tax records about how I self-assessed things, and if ever asked (unlikely) I will provide those as why I did not lodge a tax return.

 

That seems entirely sensible to me !   Happily in late-2023, I changed the basis of my retirement-extensions from monthly-transfers to B800k on-deposit in-the-bank, so my registered-transfers from my overseas-bank to my Thai-bank this year are very-much reduced, to below the B0.5-million or so which are covered by my allowances & zero-rate tax-band.

 

And I keep a running-note of those transfers, just in-case they ever ask to see them, although they are already aware of them from my Thai-bank's reporting.

 

28 minutes ago, TroubleandGrumpy said:

 

Plus any money I send to my Thai Wife in Thailand (under 20 million) is not taxable under the TRD gift rule - that is true as long as it goes into her bank account and is spent by her on things like a house, car, shopping, golf, etc etc (and she does not transfer any money to my account). 

 

Agreed  ...  also our electricity/phone-bills are paid out of a dedicated BKK-Bank account, which is solely in her name.  I occasionally make a Gift-to-Wife transfer from overseas, into that account.  What a kind fellow !

 

And the chances of dear-wifie ever making a transfer into my local bank-account, well pigs might fly !  :cool:

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Posted
21 minutes ago, NoDisplayName said:

 

I think you're mistaken a mutual fund purchased from a bank or brokerage with some sort of IRA.

I can see why you would say that, but a mutual fund such as a Superannuation Fund, is not something any individual can do by themselves. They are not an IRA and they are also not an employer created 401K like in USA.

 

In Australia, and other places. a Super Fund is controlled by the Govt and it is mandated that employers contribute to the Fund selected by the employee, plus the employee can input additional funds to his Fund account (with some Govt restrictions). The Super Fund pays taxes to the Govt on the total earnings made by the Fund over each financial year (with some exclusions). Essentially they are a savings account made mandatory by the Govt so that not everyone needs the Govt Pension. In reality, when most people retire get some Super money and some Govt Pension.

 

But when it comes to most European countries, their retirement funds are a whole different ball game - very complex.  

Posted
31 minutes ago, Ricardo said:

 

That seems entirely sensible to me !   Happily in late-2023, I changed the basis of my retirement-extensions from monthly-transfers to B800k on-deposit in-the-bank, so my registered-transfers from my overseas-bank to my Thai-bank this year are very-much reduced, to below the B0.5-million or so which are covered by my allowances & zero-rate tax-band.

 

And I keep a running-note of those transfers, just in-case they ever ask to see them, although they are already aware of them from my Thai-bank's reporting.

 

 

Agreed  ...  also our electricity/phone-bills are paid out of a dedicated BKK-Bank account, which is solely in her name.  I occasionally make a Gift-to-Wife transfer from overseas, into that account.  What a kind fellow !

 

And the chances of dear-wifie ever making a transfer into my local bank-account, well pigs might fly !  :cool:

Well done mate - we are on the same page 😉  I wish more Expats would do the work to analyse their own situation and work out how best to avoid TRD.  The Thai tax system is very accommodating - especially to those married to a Thai.  That is one reason why an Expat can 'gift' up to 20 Million Baht to his wife from overseas (and 10 million to each kid), and she and the kids do not have to pay any income tax on that money. That rule may be changed if/when it gets used a bit, but most of the pundits think they will only lower the amounts - perhaps to 10 and 5 million. The blowback from those 'elite' Thais who use that gift rule would be horrendous if the Thai Govt tried to drop it completely.   

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Posted
3 minutes ago, TroubleandGrumpy said:

I can see why you would say that, but a mutual fund such as a Superannuation Fund, is not something any individual can do by themselves. They are not an IRA and they are also not an employer created 401K like in USA.

 

In Australia, and other places. a Super Fund is controlled by the Govt and it is mandated that employers contribute to the Fund selected by the employee, plus the employee can input additional funds to his Fund account (with some Govt restrictions). The Super Fund pays taxes to the Govt on the total earnings made by the Fund over each financial year (with some exclusions). Essentially they are a savings account made mandatory by the Govt so that not everyone needs the Govt Pension. In reality, when most people retire get some Super money and some Govt Pension.

 

But when it comes to most European countries, their retirement funds are a whole different ball game - very complex.  

 

Well, okay then.  We need to do the immigration terminology thing here.  ("You have an extension of stay, not a visa")

 

For most, mutual funds/ETF's are investment products sold by banks and brokerages for investment purposes.

 

If we mean government programs, we'd say IRA or Roth or........superannuation or 401(k).  I think Thailand has a version of that called an RMA you can purchase through the banks.  Labeling any of these programs a simple "mutual fund" would be confusing.

Posted
1 hour ago, TroubleandGrumpy said:

I admire posters who think anyone else's opinion is stupid and/or wrong.  But I do understand how a bloke living in a small apartment in Pattaya/Patong and who never interacts with Thais other than a BG would have no idea how things work.  If I was in that situation I would listen to those who are married to a Thai, have lived in Thailand for a long time, and who have lost of interactions with Thais people themselves. Especially those whose Thai family and friends is also proving them with their opinions and advice, and who are asking other Thais about this new tax issue - because it directly affects them.   

That is not sarcasm.

Anyone who uses a bar girl as their point of reference for Thai tax, cannot be credible.

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Posted
49 minutes ago, NoDisplayName said:

 

Well, okay then.  We need to do the immigration terminology thing here.  ("You have an extension of stay, not a visa")

 

For most, mutual funds/ETF's are investment products sold by banks and brokerages for investment purposes.

 

If we mean government programs, we'd say IRA or Roth or........superannuation or 401(k).  I think Thailand has a version of that called an RMA you can purchase through the banks.  Labeling any of these programs a simple "mutual fund" would be confusing.

True - and it is very confusing - and as far as I am aware TRD has not provided a specific statement or ruling on what is a mutual or provident fund - whether it is in Thailand or Overseas.  However it has published one ruling on whether the money received by a retiree of a mutual/provident fund is taxable - and that ruling is that it is excluded as it applies to a tax return. Therefore the 'definition' used by TRD on its website as it being exempted, is what I am running with.

 

If any money or benefits received by the Fund members from the Fund on an annual basis are in accordance with the Law on Provident Funds. By retirement or retirement according to the regulations, the applicant must be at least fifty-five years old and have been a member of the Fund for at least 5 consecutive years. If the member has been a member for less than 5 consecutive years, he must be a member until the membership period is not less than 5 consecutive years, and any such money or benefit shall be exempted from calculation according to Section 42 (17) of the Revenue Code, together with Clause 2 (36) of the Ministerial Regulation No. 126 and Clause 3 and Clause 4 of the Notification of the Director-General of the Revenue Department on Income Tax (No. 223) dated October 25, 2012 as follows: The Fund is not obliged to withhold income tax under Section 50 (1) of the Revenue Code.

The Revenue Department (rd.go.th)

 

Posted
3 hours ago, chiang mai said:

One last time, from the article, which reports on fiscal year totals, NOT the tax year:

 

"In fiscal 2023, which ended on Sept 30, 2023, the Revenue Department collected a total of 2.21 trillion baht in taxes, exceeding the target by 9% and surpassing the previous year's figure by 2.1%.

In terms of major tax categories, corporate income tax revenue amounted to 767 billion baht, 13.8% above the target and 5.3% higher than the previous year.

 

Value-added tax revenue totalled 913 billion baht, 5.1% above the target, but 1.8% lower than the previous year.

 

Personal income tax revenue tallied 395 billion baht, 10.9% above the target and 7.5% higher than the previous year, while petroleum income tax revenue was 48.7 billion baht, 25.1% above the target, but 22.4% lower than the previous year".


Please credit and share this article with others using this link: https://www.bangkokpost.com/business/general/2799906/tax-refunds-delayed-by-surge-in-fake-submissions. View our policies at http://goo.gl/9HgTd and http://goo.gl/ou6Ip. © Bangkok Post PCL. All rights reserved.

 

From BP:

"There were 11.9 million personal income tax forms filed for the income year 2023, submitted between Jan 1 and April 29, 2024, an increase of 3.34% from the same period last year."

 

Increased filing is certainly subsequent of fall 2023 announcements.

 

The article is misleading as it's mixing corporate and personal income tax information.

 

PIT is calculated with data collected during the full calendar year. There is no way to extract a specific period from individual tax returns. Applying a 9/12 coefficient to get a Fiscal Year approximate amount would be imo absurd.

 

Whatever. Tax has increased. Fine.

You assume that it could be because of the concrete actions (audits, penalties, ...) taken by TRD during 2023, that you can't factually back up.

I assume it's not. I think it's because of the increase of filings (fact) and possibly that people who filed made more money (my guess).

 

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