Taxation of worldwide income for Thailand Tax Residents?

[Presnock]

13 hours ago, JohnnyBD said:

I respectfully disagree that it has always been the goal to have expats pay income taxes on their worldwide income. All the past and present rules only applys to remitted foreign income, and not one's total income earned in one's home country, or outside of Thailand. Maybe it was their goal to have Thai citizens pay taxes on income earned outside Thailand.

Anyone that is not aware of it, Thailand is working to meet all the requirements for becoming a full member of OECD and as such, last year there were several articles of interviews with the officials of the TRD and Finance Office.  By googling those offices' interviews about this very fact, one can see that their goal is to include ALL tax residents' worldwide income for taxes whether or not it is remitted.  I too realize that right now they are facing a real shortage in tax collection after the change to last year's tax rules - now a relaxtion as they call it to include a change to both last year and this year's taxes which we won't know fully until the final decree is published, but it looks like no remittances will be taxed either both years (2024 and 2025) or one only.  I sure do not what the decree will say nor do I really care as it will not affect me but I also won't write any further messages to alert folks to an article on this.  Good luck to you all.

[buddy2010]

2 hours ago, Presnock said:

Wer es noch nicht weiß: Thailand arbeitet daran, alle Voraussetzungen für eine Vollmitgliedschaft in der OECD zu erfüllen. Daher erschienen im letzten Jahr mehrere Artikel mit Interviews mit Vertretern des TRD und des Finanzamtes. Googelt man die Interviews dieser Ämter zu diesem Thema, erkennt man, dass ihr Ziel darin besteht, das weltweite Einkommen ALLER Steuerinländer zu versteuern, unabhängig davon, ob es abgeführt wird oder nicht. Mir ist auch bewusst, dass sie nach der Änderung der Steuervorschriften des letzten Jahres – einer Lockerung, wie sie es nennen – derzeit mit einem erheblichen Engpass bei der Steuereinnahme konfrontiert sind. Die Steueränderungen sowohl des letzten als auch des laufenden Jahres werden wir erst mit der Veröffentlichung des endgültigen Erlasses genau wissen. Es sieht jedoch so aus, als würden weder in beiden Jahren (2024 und 2025) noch in einem Jahr Überweisungen besteuert. Ich weiß nicht genau, was der Erlass beinhalten wird, und es interessiert mich auch nicht wirklich, da er mich nicht betrifft. Ich werde aber auch keine weiteren Nachrichten schreiben, um auf einen entsprechenden Artikel aufmerksam zu machen. Viel Glück euch allen.

 

"However, it looks as if remittances will not be taxed in either year (2024 and 2025) or in one year."

 

Sorry, but 2024 was already taxed according to the law in force at that time!

[Presnock]

1 hour ago, buddy2010 said:

 

"However, it looks as if remittances will not be taxed in either year (2024 and 2025) or in one year."

 

Sorry, but 2024 was already taxed according to the law in force at that time!

and the article mentioned that if one did pay tax in 2024 they might be allowed to file for a refund - have to wait for the final decree to see

 

[ujayujay]

Important to know: ...."The Revenue Department is preparing to draft legislation......."...

This means that the new tax system has not yet been approved by Parliament!

 

So: Wait and drink a beer🍻

[Presnock]

On 5/22/2025 at 10:28 AM, JohnnyBD said:

I haven't seen any recent articles or announcements from the Thai gov't about taxing worldwide income of tax residents. Maybe the ww taxation idea was put on the back burner in favor of the new proposal to not tax remitted income.

Yes very few now but last year with each new finance, they ref the OECD goals and mention the worldwide taxes.  What they do say here is that all Thai residents are supposed to be taxed on their total income and that expats will be treated the same as Thai nationals .

[Presnock]

1 hour ago, ujayujay said:

Important to know: ...."The Revenue Department is preparing to draft legislation......."...

This means that the new tax system has not yet been approved by Parliament!

 

So: Wait and drink a beer🍻

read it again is preparing a draft for the royal pardon of the latest which will be one or two years of remitted taxes or maybe not if the decree says something entirely different.  Once the Royal Decree is made in the Royal Gazette, it is law if I am not mistaken.

[BKKBike09]

It all seems to be more flip-flop decision making on the fly.

 

Anyone who has spent any time in Thailand should be well aware that the worst thing to do is to try and comply with a newly-introduced regulation before the officials that enforce it have received clear guidance as to how to interpret and administer - which they may never get.

 

Just consider the endless threads about the differences in interpretation of various visa regultions by different immigration offices. 

 

If they are really going to say "money bought in the same tax year as it is earned or the next year is tax free" then that's good news. Who's to say when said money was earned, especially since by implication the remittances would not need to be declared on tax return (if you file one).

 

The wrinkle I see is 'what does this means for income earned in the past and then remitted': currently if earned before 1 January 2024 it is not taxable. That to me is more of a concern.

 

However I still feel best approach is do nothing with officialdom until directly asked to. 

 

 

[ukrules]

1 hour ago, Presnock said:

read it again is preparing a draft for the royal pardon of the latest which will be one or two years of remitted taxes or maybe not if the decree says something entirely different.  Once the Royal Decree is made in the Royal Gazette, it is law if I am not mistaken.

Indeed, this is the emergency procedure and bypasses full parliamentary scrutiny and a vote.

 

So long as the 'Cabinet' agree in their little vote then it can be forwarded to the Kings departments for review, approval and eventual publication in the gazette.

 

If it's not approved then you will never hear anything spoken about this again because that would potentially be illegal.

In fact it will never be reported that it's been sent for approval unless it's already been given the nod in advance.

So one day out of nowhere it will either be published in the gazette or announced that it's being published - or nothing.

[Unamerican]

22 hours ago, Presnock said:

I have read for several years now.

Whilst I have been reading  (many things) for numerous decades by now! 

[Unamerican]

2 hours ago, Presnock said:

read it again is preparing a draft for the royal pardon

So now we need a pardon! ?? And from a Royal!
And is that “I read” or “read it!” ?? 

[Unamerican]

5 hours ago, buddy2010 said:

Sorry, but 2024 was already taxed according to the law in force at that time!

But we can fix that! 
And what laws, where? 

[Unamerican]

8 hours ago, Presnock said:

Good luck to you all.

Good to know that  we have heard the last from you too! 

[Unamerican]

20 hours ago, NoDisplayName said:

The US has a global tax system where all worldwide income must be reported.

By whom?? And to whom??  Are they taxing me, even? 

[Unamerican]

21 hours ago, tlcwaterfall said:

With respect to you it would be easier to read if you used paragraphs.

Even better if he just shuts up completely! ! 
 

And yes, it would be a great service to fidelity and truth if this entire, bogus thread was deleted: MODERATORS, please note these requests! 

[TheAppletons]

Another asinine tax speculation thread.  Yawn.

[Presnock]

59 minutes ago, Unamerican said:

So now we need a pardon! ?? And from a Royal!
And is that “I read” or “read it!” ?? 

well just like the LTR, foreign income is by Royal Decree not taxed (that is the pardon - i.e. forgiven)

[Magictoad]

23 hours ago, NanLaew said:

 

So it wasn't malware after all.

No. It was the misspelling of the URL as I mentioned in a later comment.  But whenever DDG refuses to connect a URL there is always the suspicion of malware/virus. However; I checked it in Chrome and got the same result; yesterday; actually and so concluded the problem was in the URL. But thank you for your interest.

[oldcpu]

11 hours ago, Presnock said:

Anyone that is not aware of it, Thailand is working to meet all the requirements for becoming a full member of OECD and as such, last year there were several articles of interviews with the officials of the TRD and Finance Office.  By googling those offices' interviews about this very fact, one can see that their goal is to include ALL tax residents' worldwide income for taxes whether or not it is remitted.

 

They have been talking about this for a long time.  It bears watching obviously, but many talked about things in Thailand never come to pass.

 

And even if it comes to pass, many of us have already structured our foreign income such any effect will be none (other than potentially a need to file a tax return in Thailand where before, having no assessable Thai income, such a Thai tax return was not needed).

[ukrules]

1 hour ago, oldcpu said:

They have been talking about this for a long time.  It bears watching obviously, but many talked about things in Thailand never come to pass.

 

True, there's also no rules (laws) around Controlled Foreign Companies by Thai tax residents and while that's the case incorporating abroad can very easily hide anything and everything under some corporate entity.

They do address this in the more 'advanced' tax systems in western nations but Thailand is so far behind in this respect it may take decades to catch up - they don't even have a proper capital gains tax - it's all personal income tax with just one list of bands.

It's almost like they made it simple because most of their accountants are idiots.

[OJAS]

9 hours ago, Presnock said:

"The Revenue Department is preparing to draft legislation......."

 

As it has been since last September, according to the following thread you initiated at that time!

 

 

[Presnock]

8 hours ago, OJAS said:

 

As it has been since last September, according to the following thread you initiated at that time!

 

 

well, according to all the forum comments I see, hardly anyone believes that this is a goal of the Thai Finance people.  I also realize, that some powerful people must also not be in favor of this so the debate continues.  If/when a new royal decree is published, I doubt it will be any clearer until it actually happens.

[kiwikeith]

On 5/22/2025 at 7:51 PM, topt said:

Why do you continue to post inaccurate stuff about global tax?

The statement made by an "anonymous source" is currently incorrect as almost anybody who has followed the tax discussions should know.

Even later in the article it states -

So the article contradicts itself.,

 

Both articles were discussed in several of the other threads before you decided to muddy the waters with your completely baseless headline.

If you  have have a tax agreement with Thailand, and you pay tax on that income in your country of earning, then it may only be subject to an adjustment in the rate you paid in your country, but according to the article you wont have to pay Tax until after 2026, correct me if im wrong, thanks.

I download my Tax certificates from the Bank and have them ready, which show I pay tax in NZ, I can also split the income with my wife

[oldcpu]

5 hours ago, Presnock said:

well, according to all the forum comments I see, hardly anyone believes that this is a goal of the Thai Finance people.  I also realize, that some powerful people must also not be in favor of this so the debate continues.  If/when a new royal decree is published, I doubt it will be any clearer until it actually happens.

 

I think most AGREE it is a goal of the "Thai Finance people". 

 

I suspect it will remain a goal for sometime to come. 

 

However i think many on this forum believe there are very wealthy influential Thai citizens who are either in Thai politics, or in Thai government positions (outside the Finance department) , or  who have significant influence with the politicians and other non-finance department officials.  These wealthy Thai citizens may have different goals, and that may in turn complicate (and quite possibly in the past has already complicated) any such goals of the "Thai Finance people"

 

Hence i suspect it is from that perspective that many of us note Thailand has many goals that do not come to pass. 

 

As  for a shift to global taxation?  Yes it might happen.  And it might not.  My view is everyone needs to consider such, and assess their own income sources, to see if any prudent non-disruptive financial planning, is appropriate.

[topt]

1 hour ago, kiwikeith said:

If you  have have a tax agreement with Thailand, and you pay tax on that income in your country of earning, then it may only be subject to an adjustment in the rate you paid in your country, but according to the article you wont have to pay Tax until after 2026, correct me if im wrong, thanks.

I download my Tax certificates from the Bank and have them ready, which show I pay tax in NZ, I can also split the income with my wife

The discussion is about a proposal. It hasn't been ratified yet.

Nothing has currently changed from the rules supposedly in place from 1/1/24.

[Presnock]

25 minutes ago, topt said:

The discussion is about a proposal. It hasn't been ratified yet.

Nothing has currently changed from the rules supposedly in place from 1/1/24.

this is true, we await the final decree as published before we will know who has to pay or not

[Presnock]

51 minutes ago, oldcpu said:

 

I think most AGREE it is a goal of the "Thai Finance people". 

 

I suspect it will remain a goal for sometime to come. 

 

However i think many on this forum believe there are very wealthy influential Thai citizens who are either in Thai politics, or in Thai government positions (outside the Finance department) , or  who have significant influence with the politicians and other non-finance department officials.  These wealthy Thai citizens may have different goals, and that may in turn complicate (and quite possibly in the past has already complicated) any such goals of the "Thai Finance people"

 

Hence i suspect it is from that perspective that many of us note Thailand has many goals that do not come to pass. 

 

As  for a shift to global taxation?  Yes it might happen.  And it might not.  My view is everyone needs to consider such, and assess their own income sources, to see if any prudent non-disruptive financial planning, is appropriate.

The primary driving force began with Settha and the OECD, Thailand already has met many of the OECD requirements for membership and the worldwide taxation is just another of those objectives for that membership.  But, right now because of changes last year, the amount of taxes paid to the revenue department was even lower and now they are scrambling for any extra money they can find, thus this possible easing for no taxes possibly on last year and this year too but right now it is just a guessing game for all until the decree is published.

[ukrules]

54 minutes ago, oldcpu said:

As  for a shift to global taxation?  Yes it might happen.  And it might not.

 

I wonder how this would work with the announced Royal Decree encouraging people to remit funds in the year they're earned AND the year after they're earned.

 

Full global taxation if you're a resident for 180 days but not for this year and next year and that would presumably roll on continuously.

 

Does this mean if I make about $150k a year from various income and investments I would need to remit all of that and then how long must it remain inside Thailand before it can be sent back out again to be reinvested?

Lots of questions. Would global earnings take into account this new announcement or would the new announcement replace it or are they two entirely different things.

 

I believe an act of parliament would need to be amended to alter the actual tax law itself, not sure if that can be done by a royal decree, does anyone know if it can?

 

[ukrules]

2 minutes ago, Presnock said:

scrambling for any extra money they can find, thus this possible easing for no taxes possibly on last year and this year too

 

That is something I was thinking of - could this be a temporary measure of something a little more permanent.

 

 

 

[Presnock]

Just now, ukrules said:

 

I wonder how this would work with the announced Royal Decree encouraging people to remit funds in the year they're earned.

 

Full global taxation if you're a resident for 180 days but not for this year and next year and that would presumably roll on continuously.

 

Does this mean if I make about $150k a year from various income and investments I would need to remit all of that and then how long must it remain inside Thailand before it can be sent back out again to be reinvested?

Lots of questions. Would global earnings take into account this new announcement or would the new announcement replace it or are they two entirely different things.

 

I believe an act of parliament would need to be amended to alter the actual tax law itself, not sure if that can be done by a royal decree, does anyone know if it can?

 

The royal decree works for the LTR so that remitted funds from foreign earnings are not taxed.  What the new decree will change is anyone's guess but it does appear that the finance folks are looking for any possible funds to make up for a possible big shortage on collection this year which ends in September 2025.

[oldcpu]

1 hour ago, Presnock said:

The primary driving force began with Settha and the OECD, Thailand already has met many of the OECD requirements for membership and the worldwide taxation is just another of those objectives for that membership.  But, right now because of changes last year, the amount of taxes paid to the revenue department was even lower and now they are scrambling for any extra money they can find, thus this possible easing for no taxes possibly on last year and this year too but right now it is just a guessing game for all until the decree is published.

 

With respect, I believe some clarification on that is needed.

 

There is no explicit OECD membership requirement mandating that a country must adopt a global taxation system (taxing worldwide income of residents, regardless of where it is earned or remitted) over a remitted taxation system (taxing only income brought into the country). The OECD does not prescribe a specific tax system as a condition for membership. Instead, OECD membership involves meeting a broad set of criteria related to economic, governance, and policy standards, including commitments to transparency, good governance, and cooperation in international tax matters.

 

To re-iterate, the OECD sets guidelines for tax cooperation, compliance, and transfer pricing rules, but it does not mandate a particular taxation system (global vs. remittance). Instead, it focuses on preventing tax avoidance, encouraging transparency, and ensuring that multinational companies pay their fair share of taxes, especially under its Base Erosion and Profit Shifting (BEPS) initiative.

 

While OECD countries tend to follow the global taxation system, this is not an explicit requirement for membership. A country can remain an OECD member while implementing a remittance-based or territorial tax system, as long as it adheres to broader OECD principles regarding transparency and anti-tax avoidance measures.

 

In Thailand’s case, the current system taxes foreign-sourced income of residents only when remitted to Thailand, and yes, proposed changes to tax worldwide income (even if not remitted) are being discussed under the excuse to align with global tax practices and OECD standards.

 

These proposals are partly motivated by Thailand’s ambition to join the OECD, suggesting that while not a formal requirement, adopting a global taxation system may be seen as aligning with OECD principles of tax fairness and transparency. However, Thailand’s existing remittance-based system is not inherently incompatible with OECD membership, as evidenced by other non-OECD countries with similar systems (e.g.,possibly  Malaysia ???  .. < unsure >  ... I think Malaysia has been a key partner state of OECD OECD since 2007 ?? (ie not a full OECD member) and I believe Malaysia still has a remitted system, although I believe it has introduced some global taxation aspects (but not all) ...  and perhaps like Thailand they are talking about full global taxation??  ... I may not be up to date here ) ... 

 

When I surfed on this, I read that some countries with a 'purported' territorial (or global) taxation system, in fact have closer to a mix of the two ( ie mix of global and remitted).  These OECD countries being Chile, Costa Rica, Ecuador, Panama, Singapore, Hong Kong, Malaysia (as already mentioned), Guatemala, Thailand (as already discussed in this thread), and to a much lessor extent Mexico.

 

But the point is, my understanding is that there is an absence of a clear OECD mandate against territorial taxation , and further some who are OECD members do not have a 'full' global taxation system, but have a mix of global and remitted.