❝[…] 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.❞