Thai gov. to tax (remitted) income from abroad for tax residents starting 2024 - Part II

[NoDisplayName]

23 minutes ago, TroubleandGrumpy said:

what is a mutual or provident fund -

 

A mutual fund is an investment fund.

 

The Provident Fund in Thailand is a specific thing under Thai law, similar to an American IRA, and may hold mutual funds.

 

The Provident Fund is a fund established for voluntary participation between companies and employees, serving as a source of funds for employees in cases such as resignation,　retirement, illness, or death. Governed by the Provident Fund Act, the Thai government　regulates the Provident Fund, ensuring the rights of employees within the fund.

https://www.personnelconsultant.co.th/en/column/2023/07/1396/

 

The term "Provident Fund" would not apply to any type of foreign accounts.  You would need to look in your DTA for relief there.

[chiang mai]

19 minutes ago, Yumthai said:

 

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).

 

It is not a 9/12 coefficient, it is the full twelve months which involves data from 9 months of one year and three months of a second year, in order to align the tax year data with the fiscal year parameters. That is a fairly normal routine practise when mapping overlapping periods. The PIT filing period is 1 January through 8 April, by 30 September there are less than 1% of returns outstanding hence taking data for the final three months of the year, from the preceding year, has almost no impact.

Edited September 9 by chiang mai

[TroubleandGrumpy]

14 minutes ago, NoDisplayName said:

 

A mutual fund is an investment fund.

 

The Provident Fund in Thailand is a specific thing under Thai law, similar to an American IRA, and may hold mutual funds.

 

The Provident Fund is a fund established for voluntary participation between companies and employees, serving as a source of funds for employees in cases such as resignation,　retirement, illness, or death. Governed by the Provident Fund Act, the Thai government　regulates the Provident Fund, ensuring the rights of employees within the fund.

https://www.personnelconsultant.co.th/en/column/2023/07/1396/

 

The term "Provident Fund" would not apply to any type of foreign accounts.  You would need to look in your DTA for relief there.

I hear you - but according to Google (and as used in many countries).

 

“Provident Fund” is a fund set up voluntarily by the employer and employee (member of the fund) to help employees save up for their retirement.

 

The issue being TRD has not provided an absolute definition of what a provident or mutual fund is - in terms of Expats paying income taxes.  Thailand's Tax Laws are very old and when it comes to matters overseas they are obsolete. Thailand is not ready to move to a global taxation system - not by a long shot. 

[NoDisplayName]

20 minutes ago, TroubleandGrumpy said:

I hear you - but according to Google (and as used in many countries).

 

“Provident Fund” is a fund set up voluntarily by the employer and employee (member of the fund) to help employees save up for their retirement.

 

The issue being TRD has not provided an absolute definition of what a provident or mutual fund is - in terms of Expats paying income taxes.  Thailand's Tax Laws are very old and when it comes to matters overseas they are obsolete. Thailand is not ready to move to a global taxation system - not by a long shot. 

 

I don't think a "google says a thing" trumps actual Thai legislation defining "provident fund."

 

But if that is the case, then i can safely deduct my donations to the "boys in the band" as an IRA contribution.

[TroubleandGrumpy]

28 minutes ago, NoDisplayName said:

 

I don't think a "google says a thing" trumps actual Thai legislation defining "provident fund."

But if that is the case, then i can safely deduct my donations to the "boys in the band" as an IRA contribution.

 

Sure - but you asked what is a provident fund - and you did not provide a link showing that the TRD Laws exclude overseas provident/mutual funds.  In the absence of any definition of a Provident/Mutual Fund that specifically excludes any Mutual/Provident Fund overseas setup under that Government Laws, then I will run with what I previously posted.

 

Plus - I will add Clause 25 of the Thai-Aust DTA that provides for non-discrimination.  National s of a Contracting State shall not be subjected in the other contracting State to any taxation or any requirement connected therewith, which is other or more burdensome than the taxation and connected requirements to which nationals of that other State in the same circumstances are or may be subjected. 

 

There is more 'exemptions' in the DTA - but that will do it for me for now, in the absence of any specific ruling or statement from TRD.  On that basis I have self-assessed that I believe that I do not have to pay income taxes in Thailand and I will keep all information and records that show why I made that self-assessment on funds I withdraw from my Australian 'Provident Mutual Fund' (Superannuation).  I have done the same regarding the Australian Government Pension money I remit into Thailand, and any bank savings money in Australia that I remit into Thailand. 

[Yumthai]

1 hour ago, chiang mai said:

It is not a 9/12 coefficient, it is the full twelve months which involves data from 9 months of one year and three months of a second year, in order to align the tax year data with the fiscal year parameters.

Individuals file aggregated total amounts per period of 12 months, how can TRD extract "9 months of one year and three months of a second year"?

[sandyf]

7 hours 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 ...

You are wrong. The law is not on foreigners per se, it is on all Thai tax residents.

The primary aim is collect revenue from high wealth individuals who may be generating income outside the country which is currently uncollected due to offshore tax avoidance.

Revenue from retired expat pensioners will pale into insignificance compared to the big fish, and the working expats should already be paying their taxes.

[Yumthai]

3 minutes ago, sandyf said:

The primary aim is collect revenue from high wealth individuals who may be generating income outside the country which is currently uncollected due to offshore tax avoidance.

Aren't they the same ones who rule this country?

[chiang mai]

32 minutes ago, Yumthai said:

Individuals file aggregated total amounts per period of 12 months, how can TRD extract "9 months of one year and three months of a second year"?

The calculation is based on quarters where the first quarter is when 99% of filings take place. The final quarter is inconsequential and can be based on the previous year ratio of final quarter to the first three. Did you never do modelling of such scenarios' where misaligned periods are normalised?

[Yumthai]

Just now, chiang mai said:

The calculation is based on quarters where the first quarter is when 99% of filings take place. The final quarter is inconsequential and can be based on the previous year ratio of final quarter to the first three. Did you never do modelling of such scenarios' where misaligned periods are normalised?

OK so their calculation is partly based on forecasting, that says it all.

[sandyf]

10 minutes ago, Yumthai said:

Aren't they the same ones who rule this country?

That would be between them and the TRD, not my business.

[stat]

19 hours ago, treetops said:

 

FATCA gives the USA info on accounts held overseas but does not give overseas governments info on USA holdings which CRS would.  However, as mentioned elsewhere, the USA is a member of the Global Forum on Transparency and Exchange of Information for Tax Purposes which is effectively the same thing as the CRS, just using different mechanics the way I read it.

Not true to my understanding, however I could be wrong . USA exchanges date to my understanding with several countries like Germany, Singapore and others.

 

Example:

https://www.iras.gov.sg/news-events/newsroom/entry-into-force-of-reciprocal-fatca-iga-with-the-united-states-of-america

 

 

[NoDisplayName]

3 hours ago, TroubleandGrumpy said:

In the absence of any definition of a Provident/Mutual Fund that specifically excludes any Mutual/Provident Fund overseas setup under that Government Laws, then I will run with what I previously posted.

 

Good luck with that if you get audited.

 

The tax website allows allowance for "Approved provident fund contributions paid by taxpayer or spouse."  Is your fund approved?

 

In Thailand, provident funds are covered under the Provident Fund Act.

 

The Provident Fund is established as a juristic person and registered. After the appointment with the fund management company, the fund must be registered with the Securities and Exchange Commission (SEC) according to the Securities and Exchange Act.

 

This is similar to allowance for life insurance and health insurance only for Thai registered companies, no capital gains tax only for SET companies.

 

Any allowance for an Australian provident fund would have to be spelled out in the THAI-OZ DTA.

 

http://www.thailawforum.com/database1/provident-fund-act.html

 

https://www.sec.or.th/EN/Documents/ActandRoyalEnactment/Act/act-pvd2015-no4.pdf

 

 

Edited September 9 by NoDisplayName

[sometimewoodworker]

6 hours ago, Yumthai said:

Increased filing is certainly subsequent of fall 2023 announcements.

Where do you get that idea? 
P161 & P162 only effect calendar 2024 and returns for that can not be submitted until 2025.

i have heard of no significant numbers of people desperately filling 2023 returns 

[Phulublub]

12 hours ago, motdaeng said:

 

 

many thais who should be paying taxes do not file tax returns,

What evidence dso you have for that?  All Thais who are in proper employment will be taxed at source by their employers!  Many of those in rural Thailand will not earn enough in cash to have any liabilty

 

12 hours ago, motdaeng said:

 

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

 

And your evidence for this is?  Many expats will be in receipt of non-assessable income through DTAs.  Even many of those who are not will be able to offset tax paid in home country which, together with Thai exemptions and allowances will also reduce their liability to zero.

 

PH

[Yumthai]

12 hours ago, sometimewoodworker said:

18 hours ago, Yumthai said:

Increased filing is certainly subsequent of fall 2023 announcements.

Where do you get that idea? 
P161 & P162 only effect calendar 2024 and returns for that can not be submitted until 2025.

i have heard of no significant numbers of people desperately filling 2023 returns 

 

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

 

From Bangkok Post:

 

"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."
 

[sometimewoodworker]

1 minute ago, Yumthai said:

 

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

 

From Bangkok Post:

 

"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."
 

Your post just demonstrates that the increase in returns are directly related to a publicised  loophole in the claims process for tax refunds and that subsequent to that the TRD are making changes to close that loophole.

 

correlation is not causation.

 

There is no published evidence that P161 and P162 have caused any significant increase in tax returns for a year where the have absolutely no effect 

 

It is not likely that any significant portion of the extra 400,000 tax returns were made by un informed foreigners.

 

if you have any actual information that there is causation I would like to see it

[Yumthai]

33 minutes ago, sometimewoodworker said:

Your post just demonstrates that the increase in returns are directly related to a publicised  loophole in the claims process for tax refunds and that subsequent to that the TRD are making changes to close that loophole.

 

correlation is not causation.

 

There is no published evidence that P161 and P162 have caused any significant increase in tax returns for a year where the have absolutely no effect 

 

It is not likely that any significant portion of the extra 400,000 tax returns were made by un informed foreigners.

 

if you have any actual information that there is causation I would like to see it

Of course not, this is my opinion.

[motdaeng]

12 hours ago, Phulublub said:

What evidence dso you have for that?  All Thais who are in proper employment will be taxed at source by their employers!  Many of those in rural Thailand will not earn enough in cash to have any liabilty

 

And your evidence for this is?  Many expats will be in receipt of non-assessable income through DTAs.  Even many of those who are not will be able to offset tax paid in home country which, together with Thai exemptions and allowances will also reduce their liability to zero.

 

i’m not entirely sure why you’re asking for proof. just a few points: do all shops and street vendors earning less than 10k per month ? are all shop's and seller's registered and paying taxes? do all thai people working in the entertainment and tourism industries pay their taxes? are illegal earnings and income from corruption and grey / side market activities subject to taxation? do all freelancers (facebook selling, etc) pay taxes? ... if you really believe that only a small portion of thais commit tax evasion and need proof of that, then i can’t help you ...

 

i agree that there are foreigners who don’t have to pay taxes due to the DTA and exemptions, or because of low pensions. however, not all countries have such generous treaties like the US with thailand, some have no treaties at all. if these individuals receive pensions certain sum of pension, they could already be paying taxes. 

 

i think it would be wrong to look the whole situation from just one perspective. there are foreign tax residents who sustain their lives in thailand also through investments, rental income (apartments/houses), stock market etc which results in paying taxes! some other situation, someone like to buy a car, land, house, or has to pay medical expenses with earnings (no savings before 31.12.2023). in all these situations, taxes must be paid ... just a reminder, taxes are progressive, ranging from 5% to 35%, which can result in a nice tax payment ... a easy, nice little earn for the TRD!

 

as we all know, this little change for the  tax law aims to close a loophole (used primarily by thai's), and we foreigners were not the reason for the law change. however, in my opinion, this does not mean that we are exempt from complying with this law. in a few years, it will become clear which group of us foreigners acted with foresight ...

[4MyEgo]

18 hours ago, TroubleandGrumpy said:

(Superannuation).

 

Nice try, but Article 19 says you will pay tax in Thailand.

 

Don't mean to be a party pooper, but it's in black and white.

[TroubleandGrumpy]

17 hours ago, NoDisplayName said:

Good luck with that if you get audited.

Thanks. Much appreciated.

 

 

[TroubleandGrumpy]

2 hours ago, 4MyEgo said:

Nice try, but Article 19 says you will pay tax in Thailand.

Don't mean to be a party pooper, but it's in black and white.

You, and many others, are IMO reading it wrong.  

 

Look more closely at the words, and then read my other post in the Aussie section.

https://aseannow.com/topic/1334092-australian-aged-pension-income-taxes-in-thailand/

 

Plus check out the tax expert's statement in the below video (38 min).

https://youtu.be/K-2sAgFNgVE?t=2297

 

I am not demanding you agree with me/us, all I am asking is that you agree I could be right or wrong (and vica versa). 

Unless TRD provides a specific statement that the Aust Age Pension is taxable income, then it is a matter of opinion.

 

Besides the tax expert in the video above, I have seen other opinions saying it is not taxable - but I have also seen others saying it is taxable. IMO the reason for that (in the absence of any TRD statement) is because the Clause is very ambiguous. As per my post in the Aussie Home Forum, other DTAs have been written, or re-written, with clear and unambiguous language - and they all state clearly that a Government Pension paid by one country is not taxable by the other - unless the person is both a tax resident and a citizen of the other country. That last point means a Thai citizen who lives in Australia for an extended period and qualifies for and gets the Aust Pension and then moves back to Thailand and gets 'portability', is liable to pay income taxes to Thailand on the Aust Pension payments. 

[4MyEgo]

3 hours ago, TroubleandGrumpy said:

You, and many others, are IMO reading it wrong.  

 

You are entitled to your opinion as I and others are, ours.

 

That said, I watched the video and from 38 to 40 minutes, he appears unsure himself, because in my opinion he contradicts himself, listen from 39.30 to 40.30.

 

From what I understood is that if it's a private pension, (Superannuation) it is not taxable in Australia, well we all know that, but if you read TRD code 40 you will see it is clearly stated that superannuation's are taxable here in Thailand.

 

It's pretty clear to me that a pension from a superannuation is taxable here in Thailand, but not in Australia. Remember superannuation's are usually invested in shares, etc and derive an income. therefore deriving an income, tax free in Australia when you are over 60 as you paid your taxes when you paid into super, no tax out after 60, but Thailand wants a slice of it, as per my understanding, and you have to agree, that superannuation's are income producing, otherwise we wouldn't have our money in them.

 

Now Age pensions paid by the government, in my opinion are not taxable in Australia, if that is your only source of income, now some here will want to debate that, and that's fine, my opinion is they aren't, but there is no real definition here of an Aged Pension and a pension, it is pensions only, that is where it gets messy, suffice to say, they shouldn't be taxing Age Pensioners

 

You can make your own interpretation of section 40.

 

Section 40

 

Assessable income is income of the following categories including any amount of tax paid by the payer of income or by any other person on behalf of a taxpayer.

 

(1) Income derived from employment, whether in the form of salary, wage, per diem, bonus, bounty, gratuity, pension, house rent allowance, monetary value of rent-free residence provided by an employer, payment of debt liability of an employee made by an employer, or any money, property or benefit derived from employment.⁴

 

https://www.rd.go.th/english/37749.html

 

 

 

 

 

[steph83]

Hi, anyone can you tell me if i can get personal allowance for my wife's daughter. She 18 years old student in university, she lives there and i provide her a financial assistance. Furthermore, we have together a daughter who is 12 years and live with us. How much allowance we can get please ?

 

Thanks for your information 🙂

[chiang mai]

15 minutes ago, steph83 said:

Hi, anyone can you tell me if i can get personal allowance for my wife's daughter. She 18 years old student in university, she lives there and i provide her a financial assistance. Furthermore, we have together a daughter who is 12 years and live with us. How much allowance we can get please ?

 

Thanks for your information 🙂

Yes, students in full time education up to age 26 years can be claimed as a deduction....60k as I recall.

 

EDIT:

 

Correction, 30k deduction for the first child, up to age 25 in full time deduction. Also, 30k for second child born after 2018. the link explains the details.

 

https://sherrings.com/personal-tax-deductions-allowances-thailand.html

Edited September 10 by chiang mai

[steph83]

1 hour ago, chiang mai said:

Yes, students in full time education up to age 26 years can be claimed as a deduction....60k as I recall.

 

EDIT:

 

Correction, 30k deduction for the first child, up to age 25 in full time deduction. Also, 30k for second child born after 2018. the link explains the details.

 

https://sherrings.com/personal-tax-deductions-allowances-thailand.html

Thank you, 30 K even she's not my daughter ?

Edited September 10 by steph83

[chiang mai]

13 minutes ago, steph83 said:

Thank you, 30 K even she's not my daughter ?

Ah, no, not if she's not your daughter or adopted by you.

[Phulublub]

21 hours ago, motdaeng said:

 

i’m not entirely sure why you’re asking for proof. just a few points: do all shops and street vendors earning less than 10k per month ? are all shop's and seller's registered and paying taxes? do all thai people working in the entertainment and tourism industries pay their taxes? are illegal earnings and income from corruption and grey / side market activities subject to taxation? do all freelancers (facebook selling, etc) pay taxes? ... if you really believe that only a small portion of thais commit tax evasion and need proof of that, then i can’t help you ...

 

i agree that there are foreigners who don’t have to pay taxes due to the DTA and exemptions, or because of low pensions. however, not all countries have such generous treaties like the US with thailand, some have no treaties at all. if these individuals receive pensions certain sum of pension, they could already be paying taxes. 

 

i think it would be wrong to look the whole situation from just one perspective. there are foreign tax residents who sustain their lives in thailand also through investments, rental income (apartments/houses), stock market etc which results in paying taxes! some other situation, someone like to buy a car, land, house, or has to pay medical expenses with earnings (no savings before 31.12.2023). in all these situations, taxes must be paid ... just a reminder, taxes are progressive, ranging from 5% to 35%, which can result in a nice tax payment ... a easy, nice little earn for the TRD!

 

as we all know, this little change for the  tax law aims to close a loophole (used primarily by thai's), and we foreigners were not the reason for the law change. however, in my opinion, this does not mean that we are exempt from complying with this law. in a few years, it will become clear which group of us foreigners acted with foresight ...

Whether the grey/black economy and small street vendors etc pay tax or not is not relevent to this change in the regulations.  For them, nothing is changing.  Similarly, foreigners (or Thais) with investment, rental, stock market etc income from within Thailand will already be paying tax or breaking existing law.  This change is ONLY germaine to those remitting funds from outside Thailand who are tax resident here.

 

PH

[TroubleandGrumpy]

18 hours ago, 4MyEgo said:

From what I understood is that if it's a private pension, (Superannuation) it is not taxable in Australia, well we all know that, but if you read TRD code 40 you will see it is clearly stated that superannuation's are taxable here in Thailand.

 

Withdrawals from Super are not taxable in Australia once you are 60+, because they are classified as savings, not salary or earnings or profits (like money in the bank) - and they have already been taxed - at a very attractive rate, but they have been taxed.  For most retired Expats with a Super Fund, that money was saved up from many years of working and it is not taxable income in Thailand - period.  (I will talk about annual growth 'earnings' below).

 

My Super Fund has provided a 'document of proof' stating what my Super balance was as of 31 December 2023 - and that money is not taxable in Thailand.  Likewise, I have not and will not be making additional contributions - so that balance will only decrease going forward.  Plus I have previously contributed into my Super Funds large amounts of money - such as from House and Car sales etc. - which have already been fully taxed and are absolutely classified as savings - even when I was only 55 and withdrew some funds.

 

What is taxable (and is taxed) in Australia, is the annual 'growth' in your share of the mutual fund - and they are taxed at 15% across the board (Super Fund pays direct to ATO). However, someone who has reached retirement age (67) and does fully retire, can 'convert' part/all of their account balance into a 'Pension Payment Account' and that account balance annual growth is not taxed - but it is counted somewhat by ATO/CLink as 'taxable income'.

 

What is potentially taxable in Thailand, just like savings in a bank, is the annual 'growth' in a Super account (less the 15% already taxed in Australia). But currently, that is only potentially taxable in Thailand if that 'growth money' is remitted into Thailand.  Starting Jan 1 2024 growth is potentially taxable as a percentage of the Super account's balance if any is brought into Thailand.  If someone 'earned' 10% growth (say $50K) then 10% of the money remitted in any year could be considered taxable (minus the 15% taxes already applied by Australia). But again, that is potentially taxable and I am not convinced that it is taxable.

 

Under a worldwide system of taxation, that whole amount of $50K could be taxable in Thailand - whether it is remitted or not - less the 15% already applied in Australia.  Prove that amount of tax has been paid?  No Chance. The Super Fund cannot detail exactly how much tax was paid by them for your account - it is done across the whole fund - not on an account by account basis.  I have tried since November last year and all I have got so far is an official letter stating exactly what my Super account balance was on 31 Dec 2024 and how much is the annual tax rate that they pay to ATO on all accounts growth. Plus I asked the ATO and they will not comply - no chance (otherwise millions would ask 'how much of my tax paid was from x-month to y-month).  So good luck under a worldwide system 'proving' that you already paid x dollars tax on your Super Fund growth from Jan 1 to Dec 31 in any given year, especially when the Aust tax year is July to June. 

 

Given I am already taxed and my Super Fund withdrawals are all not taxable in Australia, I think you can deduce where the money that I will be gifting to my Wife has and will come from going forward 😉

[TroubleandGrumpy]

19 hours ago, 4MyEgo said:

You can make your own interpretation of section 40.

 

Section 40

Assessable income is income of the following categories including any amount of tax paid by the payer of income or by any other person on behalf of a taxpayer.

(1) Income derived from employment, whether in the form of salary, wage, per diem, bonus, bounty, gratuity, pension, house rent allowance, monetary value of rent-free residence provided by an employer, payment of debt liability of an employee made by an employer, or any money, property or benefit derived from employment.⁴

 

Quote  "Income derived from employment ..........".  That is only applicable to salary received as a pension for work performed AFTER 1 Jan 2024.  In other words, you are not taxed on salary earned before 1 Jan 2024.  Or are you saying we have to pay taxes in Thailand on money we earned in 2000 that was put into a Super Fund?  No mate - money earned before 1 Jan 2024 is exempt from the new rule.

 

Section 41 A taxpayer who in the previous tax year derived assessable income under Section 40 from an employment, or from business carried on in Thailand, or from business of an employer residing in Thailand, or from a property situated in Thailand shall pay tax in accordance with the provisions of this Part, whether such income is paid within or outside Thailand.

Section 38_64 | The Revenue Department (English Site) (rd.go.th)

 

Likewise, under the CRS rules as per Thailand's participation, Super Funds are excluded from the reporting requirement.

 

Appendix A: Definition of Excluded Account The term Excluded Account means any of the following accounts: a. retirement or pension account that satisfies the following requirements:

i. the account is subject to regulation as a personal retirement account or is part of a registered or regulated retirement or pension plan for the provision of retirement or pension benefits (including disability or death benefits);

ii. the account is tax-favoured (i.e., contributions to the account that would otherwise be subject to tax are deductible or excluded from the gross income of the account holder or taxed at a reduced rate, or taxation of investment income from the account is deferred or taxed at a reduced rate);

iii. information reporting is required to the tax authorities with respect to the account;

iv. withdrawals are conditioned on reaching a specified retirement age, disability, or death, or penalties apply to withdrawals made before such specified events; and

v. either (I) annual contributions are limited to THB 1,500,000 or less, or (ii) there is a maximum lifetime contribution limit to the account of THB 30,000,000 or less, in each case applying the rules set forth in Section 5.2.7 Account Aggregation and 5.2.8 Currency Translation Rule

 Thailand_CRS_Guidance_280823.pdf (rd.go.th)  Appendix A on Page 65

 

I have a done a LOT more research - I could give a lot more info to back up my opinions, but the wife and lunch beckons.  I certainly am not saying I am 100% correct - but the level of errors, omissions and ambiguity in the TRD documents, is the worst/most ever in my experience - and I have studied/read a lot of complicated Govt and Legal documents.  This is going to be a clusterpharrk of extreme proportions IMO unless TRD and/or Thai Govt make some rational decisions and publicly state them.  Avoiding TRD for a few years is definitely my strategy - as long as reasonable self assessments have been done - and all records kept, just in case TRD asks for an explanation.