A foreign airline plans to open a base in Bangkok next year and operate long-haul flights to Europe. They'll use European pilots who will be hired as contractors and based in Bangkok. Salaries will be paid in Euros directly by the foreign airline. Personal tax liabilities in Thailand will be the responsibility of the contractor.

The nature of the job means that pilots will be resident in Thailand for periods aggregating less than 180 days in each calendar year, therefore they will be classed as 'non-resident'. Non-residents are subject only to tax on income from sources within Thailand.

Since the source of income is outside Thailand, i.e. a foreign airline based in Europe, personal tax liability will be zero - correct?

Or will the Revenue Department most likely take a different view?

Many thanks in advance.

That is correct, the tax liability is zero

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