Report Foreign Earnings Taxed Under New Thai Rules - But With Exceptions

[Captor]

 J

[NoDisplayName]

1 minute ago, The Cyclist said:

 

Well done trigger.

 

It would be absolutely beyond you  to think 175 days in each Country.

 

 

 

Oh, so now you're evading taxes?

Isn't that unlegal?

Shirley, the OECD has ways to handle that!

[Captor]

3 hours ago, wensiensheng said:

Not sure I follow you tbh. If your pension or salary from back home is immediately remitted to Thailand, it would be tax free. If you did that now, it would be taxed. How is that not a win.

 

Of course, if you don’t bring all your salary or pension into Thailand in the year it’s received, it would be taxed. Just as it would be now. So no loss there.

 

Quite a bit to celebrate I think.

If I want to keep (or part of it) my salary in home country for buying stocks it becomes taxable later on when I want to bring it to Thailand. So not so much to celebrate. Only that what we bring in same or next year is excemt from tax. It was better before 2024. For me at least.

[The Cyclist]

1 minute ago, NoDisplayName said:

Oh, so now you're evading taxes?

 

As all my income is taxed in the UK, I cannot possibly be evading tax.

 

But by setting up with a philippines address, it means that when I claim my State Pension ( If it's not means tested by then ) I will get the annual uplifts.

 

You really are being rather stupid.

[NoDisplayName]

2 minutes ago, The Cyclist said:

As all my income is taxed in the UK, I cannot possibly be evading tax.

 

In that case, why worry?  None of this will affect you.

 

Just file a Thai tax return and claim your tax credits for the tax Thailand is not imposing on you.

[NoDisplayName]

6 minutes ago, Captor said:

If I want to keep (or part of it) my salary in home country for buying stocks it becomes taxable later on when I want to bring it to Thailand. So not so much to celebrate. Only that what we bring in same or next year is exsemt from tax. It was better before 2024. For me at least.

 

We don't know the details yet.  There is nothing to say this is a one-off exemption, and that this will not be a rolling 2-year window to remit current income.

 

It was a journalist who added the "for instance" in the original article.

 

Under these new rules, foreign income earned and remitted within the same or following year will not incur tax. For instance, income from 2025 brought into Thailand in either 2025 or 2026 would not be taxed. Beyond this timeframe, usual tax rules will apply.

[The Cyclist]

1 minute ago, NoDisplayName said:

In that case, why worry?  None of this will affect you.

 

I'm not worrying.

 

2 minutes ago, NoDisplayName said:

Just file a Thai tax return and claim your tax credits for the tax Thailand is not imposing on you.

 

Yes, I could do that.

 

But the idea of splitting my time between both Countries is beginning to grow on me.

 

SRRV is only $10,000, with a pension of $800 a month and $300 to renew annually, what's not to like.

[ronnie50]

Not sure if anyone copied this over yet. This is the key point from the 'roadmap' link in that earlier OECD press release someone shared from last year about Thailand's accession with respect to taxation

 

Committee on Fiscal Affairs

 

• Eliminating international double taxation on income and capital without creating opportunities for non-taxation or reduced taxation through complying with the key substantive conditions underlying the OECD Model Tax Convention;

 

Here is the whole OECD document on Thailand (I'll save you some time - taxation is mentioned 22 times and only in this Committee on Fiscal Affairs section - and it never puts the words "income" and "Taxation" together. However this bullet point, with my emphasis added, is clear enough - Thailand must ensure there is no double taxation, but it cannot offer loopholes or tax-free workarounds. https://one.oecd.org/document/C(2024)118/FINAL/en/pdf

 

The one good thing from the earlier OECD press release is that there is no deadline to complete the roadmap requirements. So they could delay that part until last.

[Presnock]

On 5/19/2025 at 8:20 PM, Lingba said:

Well that article was clear as mud

IMHO so I am just guessing about all the unclear interviews/articles - if in the Thai language then the translator has a poor language translation abilitiy and if it was in English, then the original speaker obviously has some problem with the Enlish language.   I have yet to see any interview written about that did not also raised as many questions as well as  it provided very few answers.  Speaking about finance issues, one would think that who ever is involved should have a clear idea of what is being said.  Of course, many are politicians so they are well acquainted with doubletalk and speaking for a long time but actually saying very few facts about whatever the issue is.

[Antti]

19 minutes ago, ronnie50 said:

Not sure if anyone copied this over yet. This is the key point from the 'roadmap' link in that earlier OECD press release someone shared from last year about Thailand's accession with respect to taxation

 

Committee on Fiscal Affairs

 

• Eliminating international double taxation on income and capital without creating opportunities for non-taxation or reduced taxation through complying with the key substantive conditions underlying the OECD Model Tax Convention;

 

Here is the whole OECD document on Thailand (I'll save you some time - taxation is mentioned 22 times and only in this Committee on Fiscal Affairs section - and it never puts the words "income" and "Taxation" together. However this bullet point, with my emphasis added, is clear enough - Thailand must ensure there is no double taxation, but it cannot offer loopholes or tax-free workarounds. https://one.oecd.org/document/C(2024)118/FINAL/en/pdf

 

The one good thing from the earlier OECD press release is that there is no deadline to complete the roadmap requirements. So they could delay that part until last.

 

According to Chat-gpt:

 

The statement:

"Eliminating international double taxation on income and capital without creating opportunities for non-taxation or reduced taxation through complying with the key substantive conditions underlying the OECD Model Tax Convention"

primarily concerns companies, but it can also apply to individuals, depending on the context.

Here’s a breakdown:

---

Primary Focus: Companies (Multinational Enterprises)

• This language is closely aligned with OECD Base Erosion and Profit Shifting (BEPS) initiatives.

• It targets corporate tax planning strategies that exploit gaps and mismatches in tax rules (e.g., treaty shopping, artificial profit shifting).

• The goal is to:

  • Avoid double taxation where the same income is taxed in two jurisdictions.

  • But prevent abuse where entities reduce or avoid taxation entirely (double non-taxation or under-taxation).

Example:

A multinational sets up a shell company in a tax treaty jurisdiction to benefit from a treaty's lower withholding tax rate—despite having no real economic activity there. The OECD aims to stop this kind of abuse.

---

Secondary Relevance: Individuals

• For individual taxpayers, especially cross-border workers or investors, double taxation agreements (DTAs) based on the OECD Model Convention:

  • Prevent income (e.g., salaries, pensions, dividends) from being taxed twice.

  • Allocate taxing rights between residence and source countries.

However, the language in your quote is more technical and policy-driven, typical of corporate anti-avoidance frameworks—not standard individual-level tax relief.

---

Conclusion:

The statement mainly concerns companies, especially multinational corporations, and reflects efforts to strike a balance between:

• Preventing double taxation (legitimate relief),

• While blocking abuse of treaties to achieve double non-taxation or artificial tax advantages.

If you have a specific use case (individual investor, business owner, etc.), I can narrow it further.

[sandyf]

2 hours ago, TroubleandGrumpy said:

"The ugly face of falangism" -  is insulting a group of people based on them being generally old white males (racist?).   Some Expats do have contempt for Thais - that is true - but the vast majority are just sometimes extremely annoyed by their ignorance and corruption (not all of the Thais are - but a lot). 

 

Regarding your silly tax avoidance comment above, I am reminded of the Bard - ""The lady doth protest too much, methinks."  And when you commented before "why should those that pay the correct tax subsidise those that don't want to pay" makes me think you panicked and lodged a tax return and paid taxes - so you want us all to do the same - and are annoyed we did not? 

You couldn't be more wrong, on all points.

[ronnie50]

9 minutes ago, Antti said:

 

According to Chat-gpt:

 

The statement:

"Eliminating international double taxation on income and capital without creating opportunities for non-taxation or reduced taxation through complying with the key substantive conditions underlying the OECD Model Tax Convention"

primarily concerns companies, but it can also apply to individuals, depending on the context.

Here’s a breakdown:

---

Primary Focus: Companies (Multinational Enterprises)

• This language is closely aligned with OECD Base Erosion and Profit Shifting (BEPS) initiatives.

• It targets corporate tax planning strategies that exploit gaps and mismatches in tax rules (e.g., treaty shopping, artificial profit shifting).

• The goal is to:

  • Avoid double taxation where the same income is taxed in two jurisdictions.

  • But prevent abuse where entities reduce or avoid taxation entirely (double non-taxation or under-taxation).

Example:

A multinational sets up a shell company in a tax treaty jurisdiction to benefit from a treaty's lower withholding tax rate—despite having no real economic activity there. The OECD aims to stop this kind of abuse.

---

Secondary Relevance: Individuals

• For individual taxpayers, especially cross-border workers or investors, double taxation agreements (DTAs) based on the OECD Model Convention:

  • Prevent income (e.g., salaries, pensions, dividends) from being taxed twice.

  • Allocate taxing rights between residence and source countries.

However, the language in your quote is more technical and policy-driven, typical of corporate anti-avoidance frameworks—not standard individual-level tax relief.

---

Conclusion:

The statement mainly concerns companies, especially multinational corporations, and reflects efforts to strike a balance between:

• Preventing double taxation (legitimate relief),

• While blocking abuse of treaties to achieve double non-taxation or artificial tax advantages.

If you have a specific use case (individual investor, business owner, etc.), I can narrow it further.

Here's is Google's AI response to the same entry (again, my emphasis added - the sources were international legal sites)

 

The statement "Eliminating international double taxation on income and capital without creating opportunities for non-taxation or reduced taxation through complying with the key substantive conditions underlying the OECD Model Tax Convention" describes a key goal in international tax policy: finding a balance between alleviating double taxation and preventing tax avoidance. This means addressing situations where income is taxed in multiple countries without also creating loopholes that allow businesses or individuals to avoid paying taxes altogether. The OECD Model Tax Convention provides a framework for achieving this, and the statement highlights the importance of adhering to its key principles. 

 

So it.s both - that's my read - and has been from the get-go. It's why the other countries in last 2 -3 years have closed the tax-free loophole on foreign resident's incomes.

 

 

[wensiensheng]

3 hours ago, Captor said:

If I want to keep (or part of it) my salary in home country for buying stocks it becomes taxable later on when I want to bring it to Thailand. So not so much to celebrate. Only that what we bring in same or next year is excemt from tax. It was better before 2024. For me at least.

What you say is true. Pre 2024 was nirvana for basically everyone because the tax on income remitted in the year it was earned, was never enforced anyway.

 

But I think the proposed situation, if it ever comes into being, is at least better than the current one. At the moment overseas income is taxed when brought into the country, whatever the year it was earned.

[ronnie50]

1 minute ago, wensiensheng said:

What you say is true. Pre 2024 was nirvana for basically everyone because the tax on income remitted in the year it was earned, was never enforced anyway.

 

But I think the proposed situation, if it ever comes into being, is at least better than the current one. At the moment overseas income is taxed when brought into the country, whatever the year it was earned.

Under this new offer though, if it gets royal ascent, it would mean a tax holiday for all foreign remittances to Thailand earned this year, right? But how do they know when it was earned??

[TroubleandGrumpy]

4 hours ago, NoDisplayName said:

They can want all they want here in the hub of discarded plans.

If the last bright idea fell short, then global taxation......that being taxes levied on foreign sourced income regardless of remittance....will be a robust failure.

Expats will leave permanently, except for those with families, in which case they'll have to remain out of country for half the year to avoid tax residency.

Thailand's wealthy elite will find ways to evade the tax altogether, as they always do.

Right now it seems we have 2 years to wait and see if/when a global tax system starts, and what it means for Expats. Until then, anything about what they will do or will not do is speculation - OK to plan ahead, but yet again, wait for the details in the land of ever changing hubs and harebrained ideas.   

[ronnie50]

I'm not remitting anything until I see this latest float published in the Royal Gazette.

[Captor]

1 hour ago, wensiensheng said:

What you say is true. Pre 2024 was nirvana for basically everyone because the tax on income remitted in the year it was earned, was never enforced anyway.

 

But I think the proposed situation, if it ever comes into being, is at least better than the current one. At the moment overseas income is taxed when brought into the country, whatever the year it was earned.

Yes, the current situation is really bad and and this new proposion is better of course. Hopefully pre 2024 taxation will be back, though 🙂.

[Yumthai]

2 hours ago, wensiensheng said:

Pre 2024 was nirvana for basically everyone because the tax on income remitted in the year it was earned, was never enforced anyway.

Tax enforcement has not changed. Still non-existent.

[ukrules]

7 hours ago, NoDisplayName said:

Oh, so now you're evading taxes?

Isn't that unlegal?

Shirley, the OECD has ways to handle that!

 

Depends on where you're originally from and how you left, where you're leaving from and arriving to and how often you move around those places.

They can never close all the gaps and won't seek to do so.

Many western countries won't 'release' you from taxation in your home country on your global assets until you're established in another country - but not all of them.

The UK is a notable exception here as it's easy to lose UK tax residency by just not being there for a while - nothing else is required at all. They don't care where you go - if you're not there then you're out.

Thailand too as all you need to do to be a non resident in Thailand is to be there for less than 180 days a year - it could be argued in a normal year that everyone (including Thai citizens) is a non resident until day 180 assuming they've been there all year - day 180 is June 29 in a 'normal year', June 28 last year due to the leap year day.

 

You can't do that if you're from a bunch of European countries of which I don't have a list and places like Australia are tightening the screws as we speak and I believe they already want proof of a new established residency before they 'release you' from their regime.

So say you come from somewhere like Thailand or the UK and spend just 177 days in Thailand, 179 in Cambodia and 14 days in Vietnam or Laos or practically anywhere else in the world during a year - who taxes you if you come from the UK or Thailand ?

If all your income is made outside those countries then the answer is nobody but it depends on where you keep it and if any is remitted and that's what this is all about.

Evasion is lying on tax forms and or even being seen to be hiding money - like large amounts of literal cash in banknotes bought in every month which aren't declared.
 

 

[worrab]

49 minutes ago, ukrules said:

The UK is a notable exception here as it's easy to lose UK tax residency by just not being there for a while - nothing else is required at all. They don't care where you go - if you're not there then you're out.

I think you may find this statement incorrect. To do this and be able to satisfy HMRC, you must cut ALL ties to the UK.

One person thought he had done this until his Will stated that he wanted to be buried or ashes scattered, I cannot remember which, in UK. That immediately tied him back to the UK and HMRC! 
HMRC will want any taxes owed whether you are there or not. I have not been there for 10 years but still have to pay taxes on pensions.

I am sure experts on this will correct me if I have got this wrong! 

[ukrules]

4 hours ago, worrab said:

I think you may find this statement incorrect. To do this and be able to satisfy HMRC, you must cut ALL ties to the UK.

One person thought he had done this until his Will stated that he wanted to be buried or ashes scattered, I cannot remember which, in UK. That immediately tied him back to the UK and HMRC! 
HMRC will want any taxes owed whether you are there or not. I have not been there for 10 years but still have to pay taxes on pensions.

I am sure experts on this will correct me if I have got this wrong! 

 

Staying in the UK for less than 15 days per year is regarded as cutting all ties to the UK but there are other rules that come into play, only if you spend between 16 and 182 days per year in the UK and it can get complicated quickly. Best not to go at all unless you're sure if you're earning a lot in that specific year.

Also these rules have evolved over time - a lot.

The current SRT (statutory residence test) has been in force since April 2013 which was 12 years ago now.

I am certain of this and if you don't go there or only ever go for a short period of time then you are 100% completely non resident.

Before April 2013 residence was decided by a 'secret cabal' based on whispers and rumours in the corridors of power - ie it was arbitrary and up to civil servants - but not any more. Their power has been removed. 15 days or less and you're out regardless of any other 'ties' - they no longer care and haven't done for a long time now.

Perhaps you're remembering the 'bad old days' ?

 

Regarding your pensions - you're going to pay tax on them until the day you die as it's UK income - even if you were a foreigner in the UK that would be the case, doesn't make you in any way a tax resident.