❝[…] The new position is that any foreign (i.e., non-Thai) source income earned outside Thailand will be subject to Thai personal income tax regardless of when it is remitted into Thailand. This changes what was a permanent exemption from taxation on such income into a mere deferred tax liability, to be paid in ANY year the income is eventually repatriated.
In addition to surprising everyone with this change, the Revenue Department has also taken an aggressive position by making the effective date January 1, 2024
[…]
Individuals having accumulated offshore income earned prior to January 1, 2023 should give considerable thought as to whether repatriation prior to December 31, 2023 may be warranted.❞
Indeed. Bad news. These seismic policy shifts probably won’t begin or end with Thailand and Malaysia. The mass acceleration of remote workers and huge crypto gains is leaving many countries around the world feeling left out of the revenue picture. There is also a rise in “advisors” trying to game the system. These countries all want their piece of the pie.
Suppose I earn foreign income while living in Thailand but leave it in a foreign bank and don’t remit it. In the following tax year, suppose I am no longer a Thai tax resident as I spend the entire year abroad. During this non-resident year, I transfer the foreign income to my Thai bank account and use it to buy property in Thailand. Then, in the subsequent year, I return to Thailand as a full-time resident and start spending the money I transferred previously. Would that money be subject to Thai taxation, considering I remitted it while I was a non-resident, but earned it while I was a tax resident?