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

[JackAlabama]

Oh man, you were so quick to start this thread. I have also posted it, but in the "tax section," not an offshore company. Could admins then remove my thread - Thailand New overseas income rules proposed

there are a few other threads having some action regarding this.

 

[Martin Everson]

Oh man, you were so quick to start this thread. I have also posted it, but in the "tax section," not an offshore company. Could admins then remove my thread - Thailand New overseas income rules proposed

I already locked your thread and redirected to this one .

 

[jafo]

hey can rule and regulate all they want lmao I not paying anyway

Thank you! That's why I come here. I don't want to feel like I am an outcast

 

[toums]

yes.
Any savings you have before you are tax resident. It works like that everywhere (at least i dont know a country where this is different).

Any saving AND income before you are tax resident, no? If you move let's say in 2025 in TH and spend 180days+ you can still bring them tax free, correct ? (without talking about this new potential law..)

also grandfathered in if living here prior.


And doesn't mean just banked, could have it in the stock market, in stable coins, in real estate, in crypto...

if you liquidate the principle is tax free.

Curious to know how you can prove / what they ask for crypto and stable.. Ok you can get a statement at the 31/12 from the CEX (binance, kraken etc..) but for cold wallet and DEX... how to justify it ?

Or just making an sell of everything (or the money you want) the 31/12 and rebuy the 01/01...

It’s still income basically means you are ok if it’s dividends as that year if you defer (which I do for 5-10yrs) is tax free if in that year you don’t live in Thailand and then there’s tax on what you remit from those funds but the beauty is that ultimately if you made money x years ago the principle even if invested is tax free when remitted - more than my life time…

Ok maybe a better reason if it's passed to get the LTR visa..

indeed, blockchain assets should even simpler to audit.
Price thb @ 31.12.2023 is the capital, everything above that is cap gains.

Or 31.12.2024 if you were not tax resident in TH for 2024.. ?

 

[Markus92]

Thailand is ended. Thai elite card is expensive, CRS, taxes, visa problems, hard combination to buy a property, problems with health insurance. Better to find a friendly country for example Cyprus, Italy, Greece, Panama, Costa Rica. Italy 90% exemption for salaries, Cyprus 17 years without taxes (only 2,65% for health), Greece 7% foreign income tax, Panama 0% foreign income tax, Costa rica 0% foreign income tax. I have European passport. I think that I will choose Italy. I will take all income as a director salary from my Seychelles company so company won't have any profits. No permanent establishment problems in Italy. Tax only from 10% of this income.

 

[DigitalAffiliate]

How does this work if individual with tax residence in Thailand owns an offshore (Seychelles) company selling software, then transfers company profits to company broker account held in offshore company name, then earns additional trading profits, does that trigger individual worldwide income tax to the individual living in Thailand? Thailand doesn't enforce PE rule, so it's a matter of holding everything in offshore company name right - no salary, no worldwide income tax to pay? Any thoughts?

 

[Markus92]

How does this work if individual with tax residence in Thailand owns an offshore (Seychelles) company selling software, then transfers company profits to company broker account held in offshore company name, then earns additional trading profits, does that trigger individual worldwide income tax to the individual living in Thailand? Thailand doesn't enforce PE rule, so it's a matter of holding everything in offshore company name right - no salary, no worldwide income tax to pay? Any thoughts?

I think that if you hold under company name you are safe. You and company are two different enitities. Thailand doesn't have CFC rules. Only one problem can be that your company is managed from Thailand so permanent establishment rules if they control but low chances in Thailand. To avoid problems you can appoint nominee director.

 

[wellington]

How does this work if individual with tax residence in Thailand owns an offshore (Seychelles) company selling software, then transfers company profits to company broker account held in offshore company name, then earns additional trading profits, does that trigger individual worldwide income tax to the individual living in Thailand? Thailand doesn't enforce PE rule, so it's a matter of holding everything in offshore company name right - no salary, no worldwide income tax to pay? Any thoughts?

Well, this is the conundrum, if you own a company overseas based on the current rulings the company isn't brought onshore unless its operating onshore, OR unless it does over a billion baht in revenue (which is the one area some people will be caught out).

Aside from that under the new ruling -> all income derived is taxable within Thailand for you personally.

 

[Markus92]

Well, this is the conundrum, if you own a company overseas based on the current rulings the company isn't brought onshore unless its operating onshore, OR unless it does over a billion baht in revenue (which is the one area some people will be caught out).

Aside from that under the new ruling -> all income derived is taxable within Thailand for you personally.

I see that you have knowledge about taxes. What do you think about my Italian solution? Should it work?

 

[wellington]

I see that you have knowledge about taxes. What do you think about my Italian solution? Should it work?

No but there is a guy on here who has had a few bouts with their tax agency so perhaps he will popup.

He’s like a genie so the best way to bring him here is by talking about crypto with dubious back ground or cash you can’t explain lol

The man the myth the legend that is John Doe

Thank you! That's why I come here. I don't want to feel like I am an outcast

Government appears to be in trouble debt wise and gdp growth wise

 

[JustAnotherNomad]

Italy 90% exemption for salaries

Pretty sure that one has already been killed/watered down. There was also some unclarity whether social security would be due on the whole amount or not.

No permanent establishment problems in Italy.

What?

 

[Markus92]

Pretty sure that one has already been killed/watered down. There was also some unclarity whether social security would be due on the whole amount or not.



What?

If you take all money as director salary the company won't have profit so no corporation tax if Italy wants to apply CFC and permanent establishment rules.

 

[JustAnotherNomad]

If you take all money as director salary

Which may not be allowed.

the company won't have profit so no corporation tax

So? What does that have to do with PE rules?

if Italy wants to apply CFC

Highly unlikely as that would mean 1/3 of the income of the company would have to be passive in nature. (Hint: You don't know what CFC rules are.)

and permanent establishment rules.

They most likely would, or just consider the company tax resident. The company would definitely have to file taxes in Italy, even if it didn't have any profit.

But anyway, let's assume you could actually take out all of the profits as a salary.
It's now only 50%, not 90%, and it's capped at a salary of 600k. You also have to stay in Italy for several years, so no way to run if you don't like it.

 

[Martin Everson]

Digital Nomads Can Now Work in Thailand for Up to Five Years​

https://www.msn.com/en-us/travel/ne...-in-thailand-for-up-to-five-years/ar-BB1nyPKc
Maybe just spend less than 180 days a year in Thailand and be done.

Btw will this new law also affect the rich folk with following Visa types?

https://www.hlbthai.com/thailand-long-term-resident-ltr-visa/

 

[Markus92]

Which may not be allowed.



So? What does that have to do with PE rules?



Highly unlikely as that would mean 1/3 of the income of the company would have to be passive in nature. (Hint: You don't know what CFC rules are.)



They most likely would, or just consider the company tax resident. The company would definitely have to file taxes in Italy, even if it didn't have any profit.

But anyway, let's assume you could actually take out all of the profits as a salary.
It's now only 50%, not 90%, and it's capped at a salary of 600k. You also have to stay in Italy for several years, so no way to run if you don't like it.

So Philippines without CRS rules and foreign tax income. On tourist visa you can live .... 3 years. The cheapest solution.

 

[JackAlabama]

Digital Nomads Can Now Work in Thailand for Up to Five Years​

https://www.msn.com/en-us/travel/ne...-in-thailand-for-up-to-five-years/ar-BB1nyPKc
Maybe just spend less than 180 days a year in Thailand and be done.

Will boil down this this.

Btw will this new law also affect the rich folk with following Visa types?

https://www.hlbthai.com/thailand-long-term-resident-ltr-visa/

not yet

 

[Benzouser]

I think no worries. . they dont have the staff to hunt down small fish . . they will target the Chines and high networth folks. . ,
I been tax resident in TH for 19yrs i dont even have a TIN there..hmm...

 

[Markus92]

One pros is that Thailand is going to get 5 years visa for digital nomads: Thailand Multiple Entry Visa for Digital Nomads: 5-Year Visa 180 days per entry. Good that I didn't buy Elite Card. I feel sorry for the people who bought it a year ago. They ended with long tourist visa and with tax on foreign income.

 

[JackAlabama]

One pros is that Thailand is going to get 5 years visa for digital nomads: Thailand Multiple Entry Visa for Digital Nomads: 5-Year Visa 180 days per entry. Good that I didn't buy Elite Card. I feel sorry for the people who bought it a year ago. They ended with long tourist visa and with tax on foreign income.

you must be new to the region if you feel sorry for these people

 

[wellington]

you must be new to the region if you feel sorry for these people

Value of Elite is simply the ability to reside at home for 5,10,15,20 etc years without having to ever leave the country, and without having to deal with IO, except once a year where they run around printing paperwork to affix a new stamp.

It's also 'peanuts' when all things considered, even on the new pricing structure.

As for everything else including tax, there's many ways to structure to offset, but these methods are not available to someone that eats as they earn.