Thailand new change - world wide income at Thai tax levels to be taxed

[liroyb]

Define 'big fish'.

It has been told that they are mainly targeting those with large capital invested in overseas securities / crypto.

The typical HNWI involved in the capital markets won't actively manage his portfolio. He will typically hold in a private bank shares of some long-term capital appreciation fund, be it active or passive (ETF) and take rolled-over lombard loan against them to cover his living expenses.

That's the typical profile of their main target.

 

[toums]

Say you earned 10m in 2021 and then reinvested 7m of that and spent 3m in between and then your 7m turned into 30m

The 7m taken out of the investment is still tax free and can be remitted anytime tax free.

The remaining 23m can be reinvested and one year you can do the old slipper roo by dancing around jurisdictions and the year after you can bring some of that 23m in

Basically the current stance

If the cretins change it to income everywhere then you do dividends in a year doing the slipper roo and bring it in as savingS

It’s essential to document everything OR if crypto have it showing via wallets

Yes but you made me confused or english language subtleties, dunno...

Even with that example it's still not clear. Ok, whatever you made 10M in 2020, 2021, 2022, or 2023 (as income), you can bring these 10M. for free in TH, right (as tax resident or not) ?

If you invested these 10M. in 2021, 2022, 2023 or 2024, and let's say you made x3, so 30M. (+20M). You can still remit the 10M. principle in TH, but the 20M capital gain is taxable in Thailand IF remitted AND you are tax resident in Thailand AND you realized these 20M. capital gain FROM 01/01/2024.

Is all are correct?

 

[Mercury]

I like your optimism

I'll correct myself: I don't think Thailand will ever in capacity to successfully enforce tax on passport/permanent residence card like US does... in my lifetime anyway.

 

[JackAlabama]

You are nowhere secure from the governments any longer not even Thailand!

nah it can all be handled but you need to know how to do it.

Define 'big fish'.

i go out on a limb and say you have high chances of fitting that criteria
On another note. The median salary is like 400 Baht a day, so many will fit this criteria. Add some margin to it.

They are targeting the big fish but it's mostly the small fish that would be affected from it:

Correct me if I'm wrong, but someone who's having most of his capital in some passive ETF which he never sells and takes against it rolled-over lombard loans for his living expenses, won't be affected at all from the new reforms, be it remittance-based or worldwide-based, since there's no ''income'', only ''paper gains'', and he lives off debt.

Did I missed something?

yes, rationality and you as falang should pay up.
Its like with the immigration office, rules are made up on the fly.

It has been told that they are mainly targeting those with large capital invested in overseas securities / crypto.

that's a bunch of baloney. Free advice: Just someone telling something does not make it true.

I'll correct myself: I don't think Thailand will ever in capacity to successfully enforce tax on passport/permanent residence card like US does... in my lifetime anyway.

totally correct. the admin seems visibly incompetent.
Or who can issue visa categories which cannibalize itself (dtv visa vs other categories). Its like me negotiating against myself in a business transaction.

 

[scooterguy]

If I learned something in this life is that you cannot rely on a single country for your entire existence, especially third world countries. It's essential to be ready to move when rules change.

If you look at the world from 50 years ago, you'll notice it was completely different. You had countries that were a dream to live in such as Venezuela. Look at Venezuela now.

Thailand was great 10 years ago, but the new rules make it not so appealing anymore. Even the new remittance based taxation is pretty bad, especially if you need to bring in capital gains.

You never really had rights in Thailand as a foreigner, but you never had obligations either. Now, there are obligations but no rights... Doesn't sound like a social contract you'd want to sign.

But new countries are looking better. Malaysia is one with the MM2H program, and it's right next door. And several countries in South America, such as Argentina, are taking the opposite direction--lowering taxes and making it easier to invest.

Maybe it's time to accept that Thailand is not a great tax residence anymore? It can be a great place to spend a few months each year though, due to still being extremely cheap and convenient.

 

[wellington]

If I learned something in this life is that you cannot rely on a single country for your entire existence, especially third world countries. It's essential to be ready to move when rules change.

If you look at the world from 50 years ago, you'll notice it was completely different. You had countries that were a dream to live in such as Venezuela. Look at Venezuela now.

Thailand was great 10 years ago, but the new rules make it not so appealing anymore. Even the new remittance based taxation is pretty bad, especially if you need to bring in capital gains.

You never really had rights in Thailand as a foreigner, but you never had obligations either. Now, there are obligations but no rights... Doesn't sound like a social contract you'd want to sign.

But new countries are looking better. Malaysia is one with the MM2H program, and it's right next door. And several countries in South America, such as Argentina, are taking the opposite direction--lowering taxes and making it easier to invest.

Maybe it's time to accept that Thailand is not a great tax residence anymore? It can be a great place to spend a few months each year though, due to still being extremely cheap and convenient.

demographics of Thailand always meant it was going to go down hill - I had just hoped there was 15 yrs left before the s**t hit the fan but with successive commie activities and the war it’s opening the opportunity for Thailand to fleece earlier.

One thing I will note the guy that does maintenance in the Yachts had his accounts frozen a few months back - he
Is wife went to bangkok and negotiated a tax repayment plan for 900k THB over so many years (just finished building his beach front home in Rayong he was telling me months before - so obviously a sizable amount of tax avoidance)

For Thais I am guessing that will be there way for foreigners I imagine it will be treated differently

For me my concern is more towards if they tax overseas income of companies you own a stake in, then naturally inheritance for the kids.

For most other things the tax and the ways around legally are there

Some details ref Gifting Tax in Thailand Gift Tax in Thailand: 2024 Guide.

i go out on a limb and say you have high chances of fitting that criteria
On another note. The median salary is like 400 Baht a day, so many will fit this criteria. Add some margin to it.

That’s what worries me

Yes but you made me confused or english language subtleties, dunno...

Even with that example it's still not clear. Ok, whatever you made 10M in 2020, 2021, 2022, or 2023 (as income), you can bring these 10M. for free in TH, right (as tax resident or not) ?

If you invested these 10M. in 2021, 2022, 2023 or 2024, and let's say you made x3, so 30M. (+20M). You can still remit the 10M. principle in TH, but the 20M capital gain is taxable in Thailand IF remitted AND you are tax resident in Thailand AND you realized these 20M. capital gain FROM 01/01/2024.

Is all are correct?

Apologies I tried to make it simple but failed

Fred was investing in shitcoins via his offshore company in 2019 he sold in 2021 and paid himself a dividends of 10m$

Fred only needed 1m and another 2m so pulled the 3m into Thailand in 2022 (new tax year) the other 7m he lent back/invested in his company offshore which went back into the shitcoin casino in 2022/23

In 2025 (current tax setup) he sells his shitcoins bought via his company (offshore) for 40m$

He pulled 1m$ for 7 years there after into Thailand

That 7m$ is tax free

The 33m$ is currently tax free

If he remits that though as it’s past 2024 he will pay remittance income tax only on the 33m$

Once the rules change

He will pay income tax without remitting on the 33m$ but the 7m$ will be tax free still.

 

[toums]

Apologies I tried to make it simple but failed

Fred was investing in shitcoins via his offshore company in 2019 he sold in 2021 and paid himself a dividends of 10m$

Fred only needed 1m and another 2m so pulled the 3m into Thailand in 2022 (new tax year) the other 7m he lent back/invested in his company offshore which went back into the shitcoin casino in 2022/23

In 2025 (current tax setup) he sells his shitcoins bought via his company (offshore) for 40m$

He pulled 1m$ for 7 years there after into Thailand

That 7m$ is tax free

The 33m$ is currently tax free

If he remits that though as it’s past 2024 he will pay remittance income tax only on the 33m$

Once the rules change

He will pay income tax without remitting on the 33m$ but the 7m$ will be tax free still.

To keep it simple :

ANY income earned before 01/01/2024 can be remitted for free in 2024 (or later) in TH, exempt of tax.

ANY income earned from 01/01/2024 remitted in TH are taxed in TH. Except the principle investment (prior 01/01/2024) who are still tax free anyway.

 

[Mercury]

ANY income earned from 01/01/2024 remitted in TH are taxed in TH. Except the principle investment (prior 01/01/2024) who are still tax free anyway.

Principle earned prior 01/01/2024 should not be mixed thereafter with interests or other income as there is no guarantee that the smart-a*s tax auditor would not see it all as income.

If you're looking for tax-free there is only one sure way with no admin burden at the moment: stay less than 180 days per year in Thailand.

 

[TheCryptoAnt]

The typical HNWI involved in the capital markets won't actively manage his portfolio. He will typically hold in a private bank shares of some long-term capital appreciation fund, be it active or passive (ETF) and take rolled-over lombard loan against them to cover his living expenses.

That's the typical profile of their main target.

lol no

 

[wellington]

lol no

I’ve gone over this a few times

Debasement pre 22 was 8% p/a

- Monetary inflation

Inflation pre Covid was 4% p/a

- variable goods/services inflation

It has been told that they are mainly targeting those with large capital invested in overseas securities / crypto.

The typical HNWI involved in the capital markets won't actively manage his portfolio. He will typically hold in a private bank shares of some long-term capital appreciation fund, be it active or passive (ETF) and take rolled-over lombard loan against them to cover his living expenses.

That's the typical profile of their main target.

Debasement pre 22 was 8% p/a

- Monetary inflation

Inflation pre Covid was 4% p/a

- variable goods/services inflation

That’s a rough 12% hurdle rate (I won’t argue about this as it’s fact and it’s not my job to argue it)

That hurdle rate will rise in line with amount of debt and the amount of refinancing that needs to happen due to the amount of liquidity required.

I’d argue the current

Debasement rate 14% and inflation rate 2% current due to the sheer amount of refinancing occurring.

The average money manager wants min 500k a year will try and grow 10% and keep 5%

That’s a negative 11% P/a

In the above you need to factor in nominal and real

I’d also argue a HNWI person is above 5m

Anything below is a optical illusion driven by debasement

When I was a kid my grandmother used to say to me 1m in the bank pays 30k a year - you can live off that yield.

Today it wouldn’t even cover the maintenance and mooring

That 1m has to yield 150k just to keep abreast with Gov debasement which is a stealth tax

Not many things outpace it, includes gold, includes real estate, etc

Actively managing is essential as nominal growth doesn’t mean real growth

 

[JackAlabama]

demographics of Thailand always meant it was going to go down hill - I had just hoped there was 15 yrs left before the s**t hit the fan but with successive commie activities and the war it’s opening the opportunity for Thailand to fleece earlier.

One thing I will note the guy that does maintenance in the Yachts had his accounts frozen a few months back - he
Is wife went to bangkok and negotiated a tax repayment plan for 900k THB over so many years (just finished building his beach front home in Rayong he was telling me months before - so obviously a sizable amount of tax avoidance)

i take it as a hint to: Dont use the bank account too much.

For Thais I am guessing that will be there way for foreigners I imagine it will be treated differently

its the same but will be more if you want to stay.

It will be clusterduck since with visa policy, everyone makes up their own rules just as they want on the fly so it will be exact the same thing but you can handle it a certain way.
Id say if you dont play, your visa will be gone.

I have my doubt it will go down tho.

Well as consequence, I will invest into another residency permit around Asia than increasing the thai stock portfolio. Even tho, I like their stock market somewhat (Operating it works pretty smoothly).

 

[wellington]

i take it as a hint to: Dont use the bank account too much.

its the same but will be more if you want to stay.

It will be clusterduck since with visa policy, everyone makes up their own rules just as they want on the fly so it will be exact the same thing but you can handle it a certain way.
Id say if you dont play, your visa will be gone.

I have my doubt it will go down tho.

Well as consequence, I will invest into another residency permit around Asia than increasing the thai stock portfolio. Even tho, I like their stock market somewhat (Operating it works pretty smoothly).

Friend in the know said a account that has more than 3000 transactions annually will flag up for manual AMOL

I’m sure that will drop over time

One thing to be very considerate of

Thailand treats tax evasion as money laundering and their ML charges are harsh

 

[JackAlabama]

Friend in the know said a account that has more than 3000 transactions annually will flag up for manual AMOL

I’m sure that will drop over time

One thing to be very considerate of

Thailand treats tax evasion as money laundering and their ML charges are harsh

yeah such nonsense doesnt surprise me. its a third world corrupt banana republic so they do what they want, they could treat it as domestic terrorism too.
Whats good is most Thais dont pay nor file, everything is prohibited but still practiced.
So whats legal or not in the books really doesnt matter that much.

Just one needs to be careful and not stick out (emphasis added). This includes staying away from the bank account for fancy operations. Easy to do if youre a foreigner with only one foot in.

For those who cant due to family or whatever ties they have, yeah its better to keep an eye on the developments.

 

[A2934]

takes against it rolled-over lombard loans

Good plan. Where do you get the lombard loan from?

Malaysia is one with the MM2H program

MM2H is very expensive, forces you to buy real estate and takes a very long-time to get (currently I think a year if I remember correctly). Its current target market is really mostly Chinese and some other Asian escapees now, but not Westerners as before

 

[yngmind]

Friend in the know said a account that has more than 3000 transactions annually will flag up for manual AMOL

I’m sure that will drop over time

One thing to be very considerate of

Thailand treats tax evasion as money laundering and their ML charges are harsh

Are you planning to stay in Thailand?

 

[JackAlabama]

Good plan. Where do you get the lombard loan from?


MM2H is very expensive, forces you to buy real estate and takes a very long-time to get (currently I think a year if I remember correctly). Its current target market is really mostly Chinese and some other Asian escapees now, but not Westerners as before

there are many mm2hs, like sarawak and sabah. But you dont need these as most likely you can make 3 months a stay with your passport.
But yeah ultimately malaysia is the same mess as thailand and rules change there on a whim too while the foreigner should fork out his cash in raw amounts..

 

[wellington]

Are you planning to stay in Thailand?

I have a sizeable credit (pre-2024) to offset tax potential (more than i can spend in my lifetime)

The only concern i have is IF they start taxing overseas companies you hold the majority interest within (without managing).

Then i'd have to consider, having said that we will likely begin spending more time in HK, Kenya, and Malaysia-Singapore-Bali from next year to give the kids a grounding culturally.

there are many mm2hs, like sarawak and sabah. But you dont need these as most likely you can make 3 months a stay with your passport.
But yeah ultimately malaysia is the same mess as thailand and rules change there on a whim too while the foreigner should fork out his cash in raw amounts..

*Not for the feint hearted below, reality is i will straight talk on this because no one wants to and likes to have their heads embeded in their asses, believing the Gov/Media.

Once the Ukraine/Russia war breaks down you'll see a lot of these Govs reduce their costs (either long-term visas or citizenships) because as we speak its like fish in the barrel, where you get chewed up if you remain in the barrel.

Germany already pushing for concessions and peace talks, from my intel point (very resourceful) Ukraine soldiers are deserting en-mass leaving their gear, two F16s already gone (one friendly fire, other shot by Russia - not released) and over 5m dead Ukrainians).

Slava(e) Ukraine, naturally every Ukrainian young and old should be on the front line defending the resources we (US, UK etc) need, to the last one - as spoken publicly recently, theres 8 trillion $ of resources in the ground that we want (US).

So once they roll over (or rather as they are currently being rolled in to pallets like slabs of meat) a lot of countries won't be able to pilfer as the world re-opens up choice wise and costs come down when the West recognises you can't take on a commodities super power without being a commodities super power yourself.

FYI this occurred today

General Apirat Kongsompong, 64, who was the commander in chief of the Royal Thai Army from 2018 to 2020, has been relieved from duty as a special military officer.
On September 10, 2024, the Royal Gazette website published a royal command announcing that three commissioned officers have been relieved from their duties as special military officers of the Ratchawallop Royal Guards Department, effective from September 6, 2024, as follows:
1. General Apirat Kongsompong: Relieved from duty as a special military officer due to resignation from government service.
2. General Narongphan Jitkaewtae: Relieved from duty as a special military officer due to transfer to serve in the Royal Security Command.
3. Colonel Mom Chao Nawapansa Yukol: Relieved from duty as a special military officer due to transfer to serve in the Royal Security Command

I won't comment on the others, but without going into details , i can say the removal of General Apirat Kongsompong is a act that shows a change in the country coming.

 

[toums]

I have a sizeable credit (pre-2024) to offset tax potential (more than i can spend in my lifetime)

The only concern i have is IF they start taxing overseas companies you hold the majority interest within (without managing).

Then i'd have to consider, having said that we will likely begin spending more time in HK, Kenya, and Malaysia-Singapore-Bali from next year to give the kids a grounding culturally.

In this situation, you would stay less than 180days a year in TH and not being officially tax residency in any other countries you mentioned (HK, Kenya, Singapore, Indonesia..) ?

 

[wellington]

In this situation, you would stay less than 180days a year in TH and not being officially tax residency in any other countries you mentioned (HK, Kenya, Singapore, Indonesia..) ?

Credit = tax exempt

Goes back to my explainer above - it’s important to determine principles and document them, might be surprised.

It appears the yanks are now pushing back against this via their proxies (think tanks)

A prominent law firm network with a presence in the USA and Asia has strongly opposed this proposal.

They argue that taxing worldwide income would deter investment in Thailand and that the Thai Revenue Department lacks jurisdiction to control assets outside the country. Implementing such a drastic policy change would require a formal amendment to Thai law, which is a complex process.

Finance Minister Pichai Chunhavajira, at the Shaping Tomorrow summit, suggested that personal and corporate income tax rates in Thailand are higher than those in competing countries and might benefit from adjustments, reported Barry Kenyon for Pattaya Mail.

 

[JackAlabama]

I have a sizeable credit (pre-2024) to offset tax potential (more than i can spend in my lifetime)

The only concern i have is IF they start taxing overseas companies you hold the majority interest within (without managing).

Then i'd have to consider, having said that we will likely begin spending more time in HK, Kenya, and Malaysia-Singapore-Bali from next year to give the kids a grounding culturally.


*Not for the feint hearted below, reality is i will straight talk on this because no one wants to and likes to have their heads embeded in their asses, believing the Gov/Media.

Once the Ukraine/Russia war breaks down you'll see a lot of these Govs reduce their costs (either long-term visas or citizenships) because as we speak its like fish in the barrel, where you get chewed up if you remain in the barrel.

Germany already pushing for concessions and peace talks, from my intel point (very resourceful) Ukraine soldiers are deserting en-mass leaving their gear, two F16s already gone (one friendly fire, other shot by Russia - not released) and over 5m dead Ukrainians).

Slava(e) Ukraine, naturally every Ukrainian young and old should be on the front line defending the resources we (US, UK etc) need, to the last one - as spoken publicly recently, theres 8 trillion $ of resources in the ground that we want (US).

So once they roll over (or rather as they are currently being rolled in to pallets like slabs of meat) a lot of countries won't be able to pilfer as the world re-opens up choice wise and costs come down when the West recognises you can't take on a commodities super power without being a commodities super power yourself.

FYI this occurred today

General Apirat Kongsompong, 64, who was the commander in chief of the Royal Thai Army from 2018 to 2020, has been relieved from duty as a special military officer.
On September 10, 2024, the Royal Gazette website published a royal command announcing that three commissioned officers have been relieved from their duties as special military officers of the Ratchawallop Royal Guards Department, effective from September 6, 2024, as follows:
1. General Apirat Kongsompong: Relieved from duty as a special military officer due to resignation from government service.
2. General Narongphan Jitkaewtae: Relieved from duty as a special military officer due to transfer to serve in the Royal Security Command.
3. Colonel Mom Chao Nawapansa Yukol: Relieved from duty as a special military officer due to transfer to serve in the Royal Security Command

I won't comment on the others, but without going into details , i can say the removal of General Apirat Kongsompong is a act that shows a change in the country coming.

im not that deep into thai politics and rather ignorant about it, nor do I know who these people are.
What change do you think this change could imply?

They argue that taxing worldwide income would deter investment in Thailand and that the Thai Revenue Department lacks jurisdiction to control assets outside the country. Implementing such a drastic policy change would require a formal amendment to Thai law, which is a complex process.

correct. About jurisdiction at the end of the day, they can try what they want, but im totally onboard it would be bad for investment.

Finance Minister Pichai Chunhavajira, at the Shaping Tomorrow summit, suggested that personal and corporate income tax rates in Thailand are higher than those in competing countries and might benefit from adjustments, reported Barry Kenyon for Pattaya Mail.

correct. Plus too much red tape (its more akin to some african countries in that regard, where setting up a company is an insanely bureaucratic process).