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Thai tax tangle: Expats warned of new rules on overseas income

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On 6/1/2026 at 6:52 PM, Ricohoc said:

Every time there is a new tax, the rewards to the government decrease over time because people adjust their habits to mitigate the tax. Foreigners are already doing it in various ways in anticipation of what may next come down the hill. The smart ones have a plan, and a Plan B and a Plan C.

Boom.

Spoken like someone who was never in such a situation so to know the reality - rather simply believe the spinning press.

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  • They will have to be knocking on my door before i fill out any of there BS

  • A lively debate where everyone left more confused than when they arrived no doubt.

  • Sounds like yet another sales pitch from "American International Tax Advisers".  

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17 minutes ago, oldcpu said:

Frankly - Death and Taxes. Can't be avoided - despite what the spinning press and those with less money are inclined to state and believe.

Tax can surely be mitigated down to 0% if well structured. It implies some concessions, as you mentioned, depending on each individual situation.

It's possible to earn a lot of money starting from scratch but generational wealth can't be preserved by continuously paying 30+ % in various taxes on income/wealth. Even with a yearly income steadily increasing with a rate over inflation, it would be very difficult.

Just look how multimillionaires/billionaires manage their finances and wealth transmission, they certainly do not pay 2 digits - if any - overall in taxes.

1 hour ago, Yumthai said:

Just look how multimillionaires/billionaires manage their finances and wealth transmission, they certainly do not pay 2 digits - if any - overall in taxes.

What do you mean by '2 digits' ? Do you mean don't pay 10% or more in taxes on their income?

I suspect you don't know many millionaires personally. .... I can't speak for billionaires, as I don't personally know any billionaires personally (unlike millionaires where I do know a fair number).

9 hours ago, oldcpu said:

What do you mean by '2 digits' ? Do you mean don't pay 10% or more in taxes on their income?

I suspect you don't know many millionaires personally. .... I can't speak for billionaires, as I don't personally know any billionaires personally (unlike millionaires where I do know a fair number).

The millionaires I personally know reside in no/territorial tax countries. Wealth/investments/business income are offshore and compounding. Tax rate is close to 0%.

How much do the millionaires you know pay in tax on their entire wealth? Not sure they share the real answer with you.

Once people have achieved a substantial amount of wealth one common practice to legally avoid paying tax (for those residing in tax hells) is just to borrow for their living expense against their assets in collateral. The more the wealth the less LTV ratio is. This works as long as the underlying assets grow at a faster rate than the interest compiles. To be on the safe side, loan can be timely refunded with extra gains as well.

1 hour ago, Yumthai said:

The millionaires I personally know reside in no/territorial tax countries. Wealth/investments/business income are offshore and compounding. Tax rate is close to 0%.

Clearly we know different demographic/employment group of millionaires.

The strategy you describe is not for the 'average' lower tier millionaire, but IMHO rather for the ultra wealthy millionaire, who may have 50-million or more. Note many millionaires are:

- Surgeons/doctors

- Lawyers

- Business owners drawing salaries

- Retirees with pension income

- Executives receiving compensation

That is the group of millionaires I know, and they pay ordinary income tax rates that are above 10%.

The borrowing strategy you noted mainly applies to people whose wealth is concentrated in appreciating assets and who have enough wealth that lenders are comfortable extending large credit facilities.

I suspect we may be using different definitions of "millionaire." Someone with a net worth of $1–5 million is quite different from someone worth $50 million, $100 million, or more. The borrowing-against-assets strategy is much more practical for the latter group than for the former.

1 hour ago, Yumthai said:

How much do the millionaires you know pay in tax on their entire wealth? Not sure they share the real answer with you.

Tax is nominally paid on one's income. Not on one's total wealth - at least that is the case in Europe, North America, and Thailand, where i have lived the past 7 decades.

1 hour ago, Yumthai said:

Once people have achieved a substantial amount of wealth one common practice to legally avoid paying tax (for those residing in tax hells) is just to borrow for their living expense against their assets in collateral. The more the wealth the less LTV ratio is. This works as long as the underlying assets grow at a faster rate than the interest compiles. To be on the safe side, loan can be timely refunded with extra gains as well.

Yes, but we are talking about different classes of millionaires.

From my perspective, the strategy you propose might apply to someone with $50 million in stocks. Instead of selling some of their stock holdings and potentially realizing capital gains, they borrow $500,000 against their portfolio. If the portfolio grows at a higher rate than the borrowing cost, their net worth can continue to increase despite the loan.

My point is that this strategy requires substantial wealth and a large margin of safety. If the market declines significantly, the value of the collateral falls while the debt remains. The borrower may face reduced borrowing capacity, margin calls (if using margin to increase their wealth), an/or be forced to sell assets at an unfavorable time.

That is why I see this as a strategy that is practical for the ultra-wealthy, but much less practical for the typical millionaire whose net worth may be only a few million dollars.

Edited by oldcpu

15 hours ago, oldcpu said:

Boom.

Spoken like someone who was never in such a situation so to know the reality - rather simply believe the spinning press.

You can't speak to my experiences because you don't know me.

Whatever has not happened for you doesn't mean it doesn't happen for anyone else.

I already have a multi-level plan in place.

Have a good one, OC.

47 minutes ago, oldcpu said:

That is why I see this as a strategy that is practical for the ultra-wealthy, but much less practical for the typical millionaire whose net worth may be only a few million dollars.

You will be surprised. The people I know range from high 6 figures to 10M liquid net worth and all achieve 0% (or close to) tax rate because they structured themselves purposely.

But yes that is not employees or pensioners, it's business owners and investors.

Tax-free structuring needs indeed the tax, financial knowledge and the will to do so but it's feasible.

2 hours ago, Yumthai said:

You will be surprised. The people I know range from high 6 figures to 10M liquid net worth and all achieve 0% (or close to) tax rate because they structured themselves purposely.

But yes that is not employees or pensioners, it's business owners and investors.

I suspect in some ways we agree, we just see this through a different lens.

I don't know anyone in the high 6 figures of global wealth, who adopt the loan strategy you noted. Nor, in fact, do I know any millionaires (in low millionaire region of 1-to-3-million global wealth) who adopt the loan strategy you note.

The wealthy people I know (other than to use loans as leverage for high yield investments, such as real estate, or use margin for some trades), typically try to a great extent try to avoid debit. In fact, many of them simply see stocks as a gamble. Their income made them wealthy, or their inheritance made them wealthy.

Clearly, as you note, we are talking different groups of millionaires. Those employed with high taxable income, vs those who instead lever their wealth (and place of living) for investments based on specific government taxation benefits.

So yes, I agree there are some millionaires who make the extra effort to lower their taxation to less than double digits, but they pay a 'price' in terms of where they can live (as they migrate to more tax friendly places) and they may, to reduce taxation, be required to invest in aspects which give less return (so to get their tax advantage). The consequence is that is not possibly what they would have invested in otherwise, and its possible a different more taxable approach, may have given them a better return, even after tax. That is a judgment and risk they have to assess.

This is not as straight forward as the spinning tax management posts/articles may suggest. Still, I do agree on the importance of legal tax management, and while I did not phrase such that way, i made a number of posts re: my approach.

So yes , I agree , if one wishes to accept some compromises, SOME (not all) millionaires can reduce their tax below double digits. I know one (albeit only one) who has done so to reduce tax below double digit legally, with full disclosure of all their wealth and income to their government. They, however, were the exception (less than double digit with full disclosure) in the circle of those I know.

2 hours ago, Yumthai said:

Tax-free structuring needs indeed the tax, financial knowledge and the will to do so but it's feasible.

Yep. Agree. It needs the will to do so. Not all want to accept the compromise to reduce their taxation, but some indeed do.

Edited by oldcpu

50 minutes ago, oldcpu said:

The consequence is that is not possibly what they would have invested in otherwise, and its possible a different more taxable approach, may have given them a better return, even after tax.

I don't know what kind of investments give better return within a non low/0 tax environment. Quite the opposite actually.

For instance, Nasdaq-100 is historically one of the highest reliable return long-term investment (outperforms S&P500, gold, RE,... only few niche/sector funds do better). If you are a non US person residing in a tax-friendly environment there is no (capital gains) tax when you sell/take profits.

54 minutes ago, Yumthai said:

I don't know what kind of investments give better return within a non low/0 tax environment. Quite the opposite actually.

It depends where one lives - and from where is one's investments.

I assumed this exchange was a global comment about millionaires (and taxes), and not ONLY about foreign expats in Thailand who are millionaires and whose DTA between Thailand and their brokerage source country does not automatically exempt one tax. ...

Different assumptions make different assessments. For some less than double digit tax may be easy, for others (depending on nationality and income/investment source) it is a totally different ball game.

The Canada-Thailand DTA, which is relevant to me, in Article 13(5) notes capital gains from Canadian shares (earned in a Canadian financial institute) are nominally Canadian tax free for non-residents of Canada, who reside in Thailand. Rather Thailand has exclusive taxation rights, and profits off of such can potentially be taxed by Thailand if remitted to Thailand (albeit other factors such as LTR-WP/WGC visa and when profit was earned and remitted can also affect this). However IF the Canadian company is with immovable property (Article 13(4) of the DTA) then Canada can tax such stocks. .... Complicated ? I find it so.

Now - suppose one with a Canadian trading account, has strong research suggesting a share price (where Canadian company business is in immovable property) is about to do some transactions that could double or more the share price value, in a very short time frame. Then it would in that case make sense to buy the stock, and take the tax hit.

This is just one such example.

54 minutes ago, Yumthai said:

For instance, Nasdaq-100 is historically one of the highest reliable return long-term investment (outperforms S&P500, gold, RE,... only few niche/sector funds do better). If you are a non US person residing in a tax-friendly environment there is no (capital gains) tax when you sell/take profits.

The Canadian-Thai DTA is a bit more nuanced. It depends if the company is associated with immovable property (as noted above).

I should also note, I am only aware of 2 Canadian financial institutes, that allow Canadians who are not resident of Canada, to have accounts for investments.

(1) Questrade (one can hold a trading margin account and/or RRIF/RRSPs (sort of like a USA 401(k)) and

(2) CI Investing Direct - they don't allow RRSP/RRIFs nor margin accounts, for non-residents of Canada but they will allow Canadian's (who are non-resident of Canada) to invest in the CI Direct funds which they manage.

Canadian banks typically mostly freeze RRIF/RRSPs /margin accounts when one ceases to be a Canadian tax resident which is very annoying for some (it was for me). One can sell their stocks, withdraw their cash, but can't buy into new investments.

The Canadian Interactive Brokers (unlike the US) does not allow non-residents of Canada to open a trading account.

... Apologies ... i diverge ... but the point is this all gets complex once one becomes an expat. Structuring one's finances in a way to legally manage ones taxes is not a straight forward process - and hence given such, some simply say to 'heck' with it, and pay the tax.

Edited by oldcpu

3 hours ago, oldcpu said:

The Canadian Interactive Brokers (unlike the US) does not allow non-residents of Canada to open a trading account.

Canadian residents who move abroad can always close their Canadian account and transfer their assets/balances to an IBKR account assigned to their new country of residence. Other international brokers/banks are also available to them.

4 hours ago, oldcpu said:

... Apologies ... i diverge ... but the point is this all gets complex once one becomes an expat. Structuring one's finances in a way to legally manage ones taxes is not a straight forward process - and hence given such, some simply say to 'heck' with it, and pay the tax.

Indeed, as I previously said tax-free structuring needs both knowledge and will.

My point was just the old adage "Nothing can be said to be certain, except death and taxes" has nowadays become partially true.

15 minutes ago, Yumthai said:

Canadian residents who move abroad can always close their Canadian account and transfer their assets/balances to an IBKR account assigned to their new country of residence. Other international brokers/banks are also available to them.

True. Its often not pleasant thou.

Consider where one has many decades of knowledge of Canadian companies , which is useful in judging which Canadian company stocks to buy, hold or sell. Having to liquidate, change to a foreign currency (with ~1% hit on currency exchange), and then trying to trade in foreign company stocks (not knowing the companys), is throwing away decades of experience in Canadian companies, and arguably increasing one's risk by gambling on foreign companies.

EDIT: the other important point is one's RRSP/RIF (US 401(k) equivalent) can not be moved to a foreign company in one's new country of residence.

15 minutes ago, Yumthai said:

Indeed, as I previously said tax-free structuring needs both knowledge and will.

We agree there.

15 minutes ago, Yumthai said:

My point was just the old adage "Nothing can be said to be certain, except death and taxes" has nowadays become partially true.

well - no adage is perfect. Still I like (who was it? Benjamin Franklin ?) wording in a 1789 letter: "... in this world nothing can be said to be certain, except death and taxes." Given the year was 1789, its done pretty well in standing the test of time.

Edited by oldcpu

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