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

[daniels27]

What is a day year?

You cannot do this for one year and then go where you want? Why? Your EU country's problem?

Why not Paraguay? Check with @NewHorizonsParaguay he is a nice guy!

 

[JackieTsan]

What is a day year?

You cannot do this for one year and then go where you want? Why? Your EU country's problem?

Why not Paraguay? Check with @NewHorizonsParaguay he is a nice guy!

Sorry I edited my original post

Yes eu country problem. that’s why I need to act.
Thank you

 

[NewHorizonsParaguay]

What is a day year?

You cannot do this for one year and then go where you want? Why? Your EU country's problem?

Why not Paraguay? Check with @NewHorizonsParaguay he is a nice guy!

From what I read, Paraguay could be helpful to you (tax residency certificate). On the Py part, your foreign income is out of their scope.

The potential problem you could face is withholding taxes on your EU passive income (dividends) from the respective EU country, as Paraguay does not have an extensive DTT network (only Spain). If it is ETF, for example, some things can be done to prevent this.

 

[JackieTsan]

From what I read, Paraguay could be helpful to you (tax residency certificate). On the Py part, your foreign income is out of their scope.

The potential problem you could face is withholding taxes on your EU passive income (dividends) from the respective EU country, as Paraguay does not have an extensive DTT network (only Spain). If it is ETF, for example, some things can be done to prevent this.

Thank you! Apologies, I mean dividends from my company, not investments (and investments too). What is the problem there with this? I am not aware at all. Many thanks

 

[NewHorizonsParaguay]

Thank you! Apologies, I mean dividends from my company, not investments (and investments too). What is the problem there with this? I am not aware at all. Many thanks

It depends on the country where the company is incorporated. Many have withholding taxes on dividends (reduced when there is a DTT). Some have different withholding tax rates when the recipient's country is considered tax-haven/noncooperative (e.g., Slovakia 35% - Paraguay is on the list of cooperative countries, tho).

 

[JackieTsan]

thank you! Where is this list? never happened to me.

 

[NewHorizonsParaguay]

thank you! Where is this list? never happened to me.

I can send you the list for Slovakia, but the list varies by the countries. It depends on where your company is incorporated.
However, Paraguay signed this agreement (with some reservations), so it should whitelisted by most countries.
https://www.oecd.org/en/topics/sub-...administrative-assistance-in-tax-matters.html

 

[daniels27]

I can send you the list for Slovakia, but the list varies by the countries. It depends on where your company is incorporated.
However, Paraguay signed this agreement (with some reservations), so it should whitelisted by most countries.
https://www.oecd.org/en/topics/sub-...administrative-assistance-in-tax-matters.html

@JackieTsan you won't have this problem as you most likely incorporated in low-tax counties that don't charge withholding tax on dividends.

 

[JackieTsan]

I can send you the list for Slovakia, but the list varies by the countries. It depends on where your company is incorporated.
However, Paraguay signed this agreement (with some reservations), so it should whitelisted by most countries.
https://www.oecd.org/en/topics/sub-...administrative-assistance-in-tax-matters.html

Thank you! I can't understand what is this...

 

[daniels27]

He is taking about this one
https://taxsummaries.pwc.com/slovak-republic/corporate/withholding-taxes

 

[JackieTsan]

He is taking about this one
https://taxsummaries.pwc.com/slovak-republic/corporate/withholding-taxes

Thank you very much @daniels27

 

[yomboloz]

We definitely paid and keep paying more than enough! That’s why I’ve decided to move and stay at max 178 days but it’s hard to find where to go not to have risks.. just found out that Georgia (not in the topic but as we discuss) does not work too so still looking for other options. Elite doesn’t give tax free. Some people think that LTR is tax free but check the rules & terms carefully and you will conclude..

Which part of the LTR tax free status do you think is not actually tax free? I am genuinely curious, since I'm thinking of going for it soon?

 

[pomo]

Interesting, I never looked in to the fine print but the relevant decree says this:

Section 5
Income tax under Part 2 of Chapter 3 in Title 2 of the Revenue Code shall be
exempted for a foreigner categorised as Wealthy Global Citizen, Wealthy Pensioner, or Work-
from-Thailand Professional who is granted a Long-Term Resident Visa under immigration law for
assessable income under section 40 of the Revenue Code derived in the previous tax year from
an employment, or from business carried on abroad, or from a property situated abroad, and
brought into Thailand.

So the tax free only applies to income from previous tax year brought in to Thailand - this is the same that everybody already had until 2024.
However if I interpret this correctly those under LTR will continue to enjoy this privilege even with the recent changes?
Also, it doesn't cover the potential scenario that global income is taxed and also not remitted.

 

[JackieTsan]

Which part of the LTR tax free status do you think is not actually tax free? I am genuinely curious, since I'm thinking of going for it soon?

Happy new year @yomboloz
Yes,
*After a quick search: LTR is exempt from foreign sourced income if remitted the following tax year.

source: https://www.expattaxthailand.com/your-questions-answered/ and a few other QAs

I'd appreciate it if you can let us know what else you might find, as I've heared a few other rules but I can't find them.

Thank you!

 

[kingxx22]

https://www.nationthailand.com/news/policy/40045152

Seems like they have more pressure to attract walethy foreigners. Chinese budget tourists turn-out lower than expected. Think I'm gonna get LTR end of year. Thai tax residence under LTR rules and offshore entity to actively trade is a pretty good combination I think. Create some substance with director and that should be pretty solid. Also could totally see a future where even if they change to world-wide income taxation they could still leave LTR rules standing not to push out capital out of the country. Benefit of LTR is that it's a separate law and isn't overwritten by the general tax changes we have seen now coming into effect.

 

[mmueller]

Happy new year @yomboloz
Yes,
*After a quick search: LTR is exempt from foreign sourced income if remitted the following tax year.

source: https://www.expattaxthailand.com/your-questions-answered/ and a few other QAs

I'd appreciate it if you can let us know what else you might find, as I've heared a few other rules but I can't find them.

Thank you!

That website seems confusing, or it is just me. Since when does CRS report individual transactions?

Also with regards to the "LTR is exempt from foreign sourced income" yeah well so is ALL foreign income when earned the previous year and then remitted, from my understanding. Up until last year when that rule was removed. So I can't see why there would be a separate exemption carved out just for LTR visa holders, this applied to everyone equally. And it is now gone. Since the rules of SEO dictate that you must never publish dates when your content was written, its entirely unclear if that website just hasn't updated to account for the new rules.

 

[pomo]

That website seems confusing, or it is just me. Since when does CRS report individual transactions?

Also with regards to the "LTR is exempt from foreign sourced income" yeah well so is ALL foreign income when earned the previous year and then remitted, from my understanding. Up until last year when that rule was removed. So I can't see why there would be a separate exemption carved out just for LTR visa holders, this applied to everyone equally. And it is now gone. Since the rules of SEO dictate that you must never publish dates when your content was written, its entirely unclear if that website just hasn't updated to account for the new rules.

I posted a link to the Royal Decree "Governing Reduction of Tax Rates and Exemption of Taxes" which spells out the special exemptions for the LTR visa in Section 5. Straight from the source, no SEO blog fluff piece. As far as I know the Revenue Department re-interpretation of the remittance rule does not override this exemption.

 

[mmueller]

I posted a link to the Royal Decree "Governing Reduction of Tax Rates and Exemption of Taxes" which spells out the special exemptions for the LTR visa in Section 5. Straight from the source, no SEO blog fluff piece. As far as I know the Revenue Department re-interpretation of the remittance rule does not override this exemption.

Thanks for the clarification. Reading up on the new visa types I note that the LTR (long-term resident) has high requirements for yearly income, qualifications and/or assets as explained here: https://ltr.boi.go.th/#what

I was slightly confused because I thought the LTR visa was the same as DTV visa, the new "Digital Nomad" visa everyone has been touting the last year. But turns out it is not, and the tax exemptions you list don't seem to be available on the DTV visa.

 

[pomo]

Thanks for the clarification. Reading up on the new visa types I note that the LTR (long-term resident) has high requirements for yearly income, qualifications and/or assets as explained here: https://ltr.boi.go.th/#what

I was slightly confused because I thought the LTR visa was the same as DTV visa, the new "Digital Nomad" visa everyone has been touting the last year. But turns out it is not, and the tax exemptions you list don't seem to be available on the DTV visa.

Yes, the exemptions only apply to the LTR visa (and even then, only a subset of the categories). I don't think that many nomads qualify for the remote work category, as even with the recent changes it still requires you have an employment contract with an entity that has an annual turnover of US$50M. The BOI page says they have 695 applications in the "Work-from-Thailand Professionals" category as of November 2024 (no data on how many of those approved).

In the "Wealthy Global Citizen" only 229 applications, guess not that many are happy to invest $500K in Thailand either.

 

[JackAlabama]

Yes, the exemptions only apply to the LTR visa (and even then, only a subset of the categories). I don't think that many nomads qualify for the remote work category, as even with the recent changes it still requires you have an employment contract with an entity that has an annual turnover of US$50M. The BOI page says they have 695 applications in the "Work-from-Thailand Professionals" category as of November 2024 (no data on how many of those approved).

In the "Wealthy Global Citizen" only 229 applications, guess not that many are happy to invest $500K in Thailand either.

well bc this 500k has a lot of characteristics of a dono (if you're foreigner).

Plus you need to declare 1M usd, might not be great for your safety either (but as they have 100k usd millionaires themselves this might be ok if you are in the rich neighbourhood).
For safety reasons, Id still tend to avoid this tho.