18 minutes ago, Yumthai said:

Next time you ask him something and he replies promptly for free, ask the tax code references that support his statement because it's contrary to the written law.

By the way, you seem to be a very important person to have a such famous international company busy director who, promptly and freely, answer and advice twice the same day a potential customer. Oh wait, I didn't see the date... it was April 1st.

Calling me a liar again, ignorant know it all pensioner? Why not admit you defeat and get lost?

6 hours ago, CallumWK said:

I asked Grant Thornton, who is the 6th largest auditor (not a lawyer) in Thailand, to confirm his previous message, as there were some pensioners on AN who claimed to know better than an auditor, and here is his answer.

i would be interesting to see what other tax firms or the TRD itself would say this case example ...

lawyers and tax experts, and even the TRD, have different interpretations when the tax law does not clearly describe a situation ...

the second letter from grant thornton is also very vaguely written and leaves a lot of room for interpretation. a clear reference to the existing tax law is missing ...

eg. if someone did not spend a single day in thailand during this tax year and brings the same year taxable money or income into thailand, should that person pay tax on this money at a later time (for example, several years later) when they become a thai tax resident? is this absurd situation really clearly and unambiguously stated in the tax law?

using a legal way (eg. loopholes) for tax optimization is not a crime ...

1 hour ago, JohnnyBD said:

I assume this is just a hypothetical situation for discussion, but one could easily avoid the Thai tax man in a non resident year by doing the following:

1. Remit foreign income earned in the same year as non resident

2. Remit pre-2024 monies

3. Remit proceeds from sale of assets in non resident year

4. Remit DTA exempted income

If one is staying less than 180 days in Thailand, one shouldn't need to remit as much money anyway.

Well it is not that easy for someone who lives here permanently, as he has to go out of his way to have non-resident years

I'm afraid I simply do not believe the Grant Thornton director's position on this.

I asked Gemini AI to run an extremely deep (and time-consuming) search requiring multiple sources from specialists, and this was her response.

(Note that the scenario I created was of a Thai tax resident who earns dividends in Singapore and then ceases to be a Thai tax resident and during that time remits the income to Thailand.)

4 minutes ago, Gaccha said:

I'm afraid I simply do not believe the Grant Thornton director's position on this.

I asked Gemini AI to run an extremely deep (and time-consuming) search requiring multiple sources from specialists, and this was her response.

(Note that the scenario I created was of a Thai tax resident who earns dividends in Singapore and then ceases to be a Thai tax resident and during that time remits the income to Thailand.)

Maybe let Gemini fill in your tax return next time

44 minutes ago, CallumWK said:

Calling me a liar again, ignorant know it all pensioner? Why not admit you defeat and get lost?

I suggest you stop trolling clowning yourself.

FYI I am no pensioner and I obviously know more about tax than you do.

17 minutes ago, Yumthai said:

I suggest you stop trolling clowning yourself.

FYI I am no pensioner and I obviously know more about tax than you do.

I never claimed to be knowledgeable about tax laws, that's why I asked a prominent auditor in Thailand, and you pretend to know even more than him. Although from your previous replies you made clear you didn't even know the difference between a lawyer and an auditor, as you repeatedly called the Grant Thornton firm lawyers.

53 minutes ago, CallumWK said:

Although from your previous replies you made clear you didn't even know the difference between a lawyer and an auditor, as you repeatedly called the Grant Thornton firm lawyers.

You're just confirming they are unqualified to give law advice.

5 minutes ago, Yumthai said:

You're just confirming they are unqualified to give law advice.

And what qualifies you? Is it your arrogance?

46 minutes ago, CallumWK said:

And what qualifies you? Is it your arrogance?

I certainly not give any advice, only reading and quoting the law.

2 hours ago, Yumthai said:

I am no pensioner and I obviously know more about tax than you do.

Chasing the dream of a carefree life in Thailand now stressing over Thai tax forms like a digital nomad.

SAD!

4 minutes ago, Celsius said:

Chasing the dream of a carefree life in Thailand now stressing over Thai tax forms like a digital nomad.

SAD!

You're talking about th OP right? I'm far from your description and certainly not worrying about life in Thailand, unlike some posters on this forum.

On 3/31/2026 at 11:03 AM, CallumWK said:

But that is my question. Obviously all money will have been earned during the years I was tax resident, but any foreign earned income isn't due any tax as long as it isn't transferred.

Then, if I'm indeed no tax resident during year 31, it would also not matter when the money was earned.

The main reason I started this thread is, that I know if I still lived in my home country, and went on a 200 day holiday, I would remain tax resident there for that year.

but any foreign earned income isn't due any tax as long as it isn't transferred.

I dont think thats correct. Only certain visas allow tax free overseas income. Remitted or not.

Weather you claim it or not is another matter.

3 minutes ago, thjames007 said:

I dont think thats correct. Only certain visas allow tax free overseas income. Remitted or not.

Just the opposite. Some visas allow tax free remittance from overseas. No visa requires paying income tax as long as the income isn't remitted.

3 hours ago, motdaeng said:

i would be interesting to see what other tax firms or the TRD itself would say this case example ...

Read my post above.

That was TRD, and another, bigger accounting firm.

On 3/31/2026 at 6:03 AM, CallumWK said:

But that is my question. Obviously all money will have been earned during the years I was tax resident, but any foreign earned income isn't due any tax as long as it isn't transferred.

Then, if I'm indeed no tax resident during year 31, it would also not matter when the money was earned.

The main reason I started this thread is, that I know if I still lived in my home country, and went on a 200 day holiday, I would remain tax resident there for that year.

The rules seem to state that it is money transferred into Thailand during a year you are tax resident, which is income taxable, no matter when the money is erned abroad after 1st Januar 2024.

EDIT: However, always check an eventual DTA (Double Taxation Agreement) between your home country and Thailand.

Just wanted to add that all money you had previous End Of the year 2023 are considered sort of grandfathers " Saving" and are exempt if you transfer them to Thailand .

There is also some other exemption to consider as transfers of donations to wife et et ...

43 minutes ago, khunPer said:

The rules seem to state that it is money transferred into Thailand during a year you are tax resident, which is income taxable, no matter when the money is erned abroad after 1st Januar 2024.

EDIT: However, always check an eventual DTA (Double Taxation Agreement) between your home country and Thailand.

Everyone has his own opinion on what is law.

What is listed is that money earned after 1 January 2024 and you were a tax resident in those years, it is taxable.

Because something isn't specifically listed in that image doesn't mean it applies or doesn't apply.

There is also not listed that you still have to pay tax when transferring during rainy days. Does that mean no tax is applicable on such days. Just use common sense.
I'm not a tax expert, hence I started this topic, but neither is any forum member active in this thread.
I think an auditor is best placed to give correct advice, since it is his job to know the tax laws.

So when some know it alls start to claim that one of the major auditing companies in the world are not qualified to provide advice on tax laws, then I lose interest.

Mods feel free to lock this thread as it has become silly now

22 minutes ago, CallumWK said:

Mods feel free to lock this thread as it has become silly now

Not silly unless you consider the original tax discussions silly as then people took similar entrenched positions irrespective of any other view - same, same but different.......

Even now there seems to be some people who have no idea of the basics - you replied to one a few posts ago.

This is another that was never 100% confirmed - I think ExpatTax disagreed that it was "all money" and said it was only actual cash in accounts but I have lost track so may be wrong - (or maybe Marco meant that but he was not clear in his wording?)

46 minutes ago, Marco100 said:

Just wanted to add that all money you had previous End Of the year 2023 are considered sort of grandfathers " Saving" and are exempt if you transfer them to Thailand .

45 minutes ago, CallumWK said:

So when some know it alls start to claim that one of the major auditing companies in the world are not qualified to provide advice on tax laws, then I lose interest.

Mods feel free to lock this thread as it has become silly now

I'm still of the view that a non resident(with no locally sourced thai income) doesn't even have an obligation to file a Thai tax return, let alone pay any tax.

Having said that, kudos to you for sharing the reply received.

Please keep the thread open, to share the other replies from the other firms you reached out to. I think that would be interesting, if any of them do reply.

48 minutes ago, CallumWK said:

There is also not listed that you still have to pay tax when transferring during rainy days. Does that mean no tax is applicable on such days. Just use common sense.

Using common sense is to believe what the current enforced law says: "A non-resident is, however, subject to tax only on income from sources in Thailand".

Ofc I stand to be corrected, if anyone can bring any true reference(s) (hearsay, wishful thinking, comment, interpretation, statement are no law) from the tax code that will make the above rule obsolete.

Not using common sense is to believe anyone, whatever his credentials/position/authority, who makes a statement that is contrary to the written law without being able to back it up with law references or case-law.

In your original post, you posed a simple question based on a very unique & specific set of circumstances which may not occur often. See your post below. One can certainly remit as much foreign earned income during a non resident year tax-free if the foreign income was earned in the same non resident year, or it is from the sale of assets in the same non resident year, or it is exempt by DTA, or it is exempt by Royal Decree 743 (LTR visa holders), or if those remittances are from pre-2024 monies, or from monies earned before one became a resident. If you believe Grant Thornton's opinion to be true, then you probably shouldn't remit any foreign income in 2027 if it was earned in years 2024 to 2026. GT's opinion is very general as evidenced by the following wording "would generally be regarded as assessable income" and "the remittance may still give rise to Thai personal income tax liability".

Everyone is entitled to their own opinion, and my opinion is that a non resident (with no Thai sourced income) doesn't have an obligation to file a Thai tax return or pay any Thai income taxes.

On 3/31/2026 at 9:46 AM, CallumWK said:

Lived here constantly for 30 years, and have yellow book/pink card and tax ID, so without doubt I'm resident for tax purposes and have to pay tax on income sent here.

Now in year 31 I decide to stay here for less than 180 days.

Is it really written in stone that for that single year I am not a tax resident, and can transfer as much money in as I want without paying income tax?

1 hour ago, Yumthai said:

Not using common sense is to believe anyone, whatever his credentials/position/authority, who makes a statement that is contrary to the written law without being able to back it up with law references or case-law.

I made clear already that not everything can be documented in a law, so most likely there will be no specific mention that if you transfer money, which you earned during a year you were tax resident, in a year when you are no tax resident is liable for income tax, because that is a loophole.

But I believe that the auditor I quoted has done a few hundred audits since 2024, of which a few may have been like what the OP is about, so he will have experience and have been in contact with several revenue departments.

How many audits in a similar circumstance have you done?

12 minutes ago, JohnnyBD said:

"the remittance may still give rise to Thai personal income tax liability".

You forgot this part

Subject to the specific facts and circumstances

37 minutes ago, CallumWK said:

I made clear already that not everything can be documented in a law, so most likely there will be no specific mention that if you transfer money, which you earned during a year you were tax resident, in a year when you are no tax resident is liable for income tax, because that is a loophole.

Authorities can't impose rules that are contrary to the law.

If they are not happy with the current rules, they need to amend the law first, then enforce the new regulation.

AI:

Based on current Thai tax regulations effective from January 1, 2024, an individual staying less than 180 days in a calendar year is considered a non-resident and is generally only taxed on income derived from sources within Thailand. Foreign-sourced income remitted by a non-resident is typically not subject to Thai personal income tax, provided it is not classified as Thai-sourced income. 

Key considerations regarding this scenario:

• Residency Status: Staying less than 180 days means you are a non-resident for tax purposes, restricting liability to Thai-sourced income.

• Remittance of Past Savings: Income earned in previous years while you were a tax resident, if brought into Thailand after you have ceased to be a resident (or while a non-resident), is generally treated as a transfer of capital/savings, not taxable income.

• 2024 Rule Change: While new rules effective January 1, 2024, strictly tax foreign income remitted by residents (180+ days), they do not generally alter the tax exemption on remittances of past savings by non-residents (under 180 days).

According to the current law and for a non-resident, foreign sourced remittances could be considered as assessable income only if it is somehow re-qualified as Thai-sourced income the year of the remittance.

“If a Thai resident earns foreign-sourced income in 2024 and brings it into Thailand in the same year or any subsequent year, they will be subject to PIT on that income, regardless of whether they are resident in Thailand at the time.”

https://taxsummaries.pwc.com/thailand/individual/significant-developments

In discussing a friends future move from the U.S. to Spain I referred to the U.S. Spanish DTA's residence article (4) -

I am not sure simply leaving Thailand for most of a Tax Year will suffice in all cases - I am not sure what the OP is proposing as a means to avoid taxation of a largish remittance will avoid all challenges. I am not sure where there country of origin, so I copy the U.S.-Thai DTA - a cursory review of the Great Britain-Thai DTA appears similar:

From the Thai-U.S. DTA Convention

ARTICLE 4 Residence

1.       For the purposes of this Convention, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, citizenship, place of management, place of incorporation, or any other criterion of a similar nature. The term also includes that State and any political subdivision or local authority thereof. The term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State. For purposes of this paragraph, an individual who is not a resident of Thailand under this paragraph, and who is a United States citizen or an alien admitted to the United States for permanent residence (a "green card" holder) is a resident of the United States only if the individual has a substantial presence, permanent home or habitual abode in the United States. If such individual is a resident of Thailand under this paragraph, he shall be considered a resident of both Contracting States and his residence for purposes of the Convention shall be determined under paragraph

2.       Where by reason of the provisions of paragraph 1, an individual is a resident of both Contracting States, then his status shall be determined as follows:

a.       he shall be deemed to be a resident of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident of the State with which his personal and economic relations are closer (center of vital interests);

b.       if the State in which he has his center of vital interests cannot be determined, or if he does not have a permanent home available to him in either State, he shall be deemed to be a resident of the State in which he has an habitual abode;

c.       if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident of the State of which he is a national;

d.       if he is a national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement.

 

From the U.S. Technical Explanation of the Convention between Thailand ad the U.S.

Paragraph 2

If, under the laws of the two Contracting States, and, thus, under paragraph 1, an

individual is deemed to be a resident of both Contracting States, a series of tie-breaker rules are

provided in paragraph 2 to determine a single State of residence for that individual. These tests

are to be applied in the order in which they are stated. The first test is based on where the

individual has a permanent home. If that test is inconclusive because the individual has a

permanent home available to him in both States, he will be considered to be a resident of the

Contracting State where his personal and economic relations are closest (i.e., the location of his

"center of vital interests"). If that test is also inconclusive, or if he does not have a permanent

home available to him in either State, he will be treated as a resident of the Contracting State

where he maintains an habitual abode. If he has an habitual abode in both States or in neither of

them, he will be treated as a resident of his Contracting State of citizenship. If he is a citizen of

both States or of neither, the matter will be considered by the competent authorities, who will

assign a single State of residence.

2 hours ago, Porthos said:

“If a Thai resident earns foreign-sourced income in 2024 and brings it into Thailand in the same year or any subsequent year, they will be subject to PIT on that income, regardless of whether they are resident in Thailand at the time.”

AI:

Your statement mentions tax applies "regardless of whether they are resident in Thailand at the time." This is incorrect in its broad phrasing:

Resident When Earned: To be taxable, the individual must have been a Thai tax resident (staying in Thailand for 180 days or more) during the year the income was earned.

Resident When Remitted: The individual must also be a Thai tax resident during the year the income is brought into Thailand to be liable for PIT on that remittance.

Exemption: Income earned while you were not a Thai tax resident is generally not taxable, even if you later bring it into Thailand as a resident

Edited.

Sorry PwC but I trust AI on that one.

2 hours ago, Porthos said:

“If a Thai resident earns foreign-sourced income in 2024 and brings it into Thailand in the same year or any subsequent year, they will be subject to PIT on that income, regardless of whether they are resident in Thailand at the time.”

https://taxsummaries.pwc.com/thailand/individual/significant-developments

That may be the law, but I don't think many non-residents have to worry about paying PIT in Thailand when a large majority of Thai residents do not file tax returns or pay PIT. The Thai Revenue Dept doesn't have the resources to audit all non-residents who visit Thailand, and probably don't have the legal authority to audit non-resident non-Thai citizens either. 😊

21 hours ago, CallumWK said:

Everyone has his own opinion on what is law.

What is listed is that money earned after 1 January 2024 and you were a tax resident in those years, it is taxable.

Because something isn't specifically listed in that image doesn't mean it applies or doesn't apply.

There is also not listed that you still have to pay tax when transferring during rainy days. Does that mean no tax is applicable on such days. Just use common sense.
I'm not a tax expert, hence I started this topic, but neither is any forum member active in this thread.
I think an auditor is best placed to give correct advice, since it is his job to know the tax laws.

So when some know it alls start to claim that one of the major auditing companies in the world are not qualified to provide advice on tax laws, then I lose interest.

Mods feel free to lock this thread as it has become silly now

So, you asked a question and I kindly tried to give you an answer, quoting the official tax advises. But why do you at all ask questions here, if you don't want other members' to reply...