Thailand’s foreign income tax changes now in force

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2025

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Thailand’s foreign income tax changes now in force

Sponsored by

hlb-thailand-2.png
geoff-greenwood-pb4pLVChwY0-unsplash (1).jpg

Starting this year, Thailand’s Revenue Department has revised its approach to taxing foreign income received by tax residents. Paul Ashburn of HLB Thailand summarises the changes

Historically, if a person was a tax resident of Thailand and they received income from offshore, they could avoid paying Thai tax on such income by receiving the income offshore and deferring any remittance into Thailand until the new year.

To address the disparity in the taxation of income from sources outside the country compared with income earned within the country, the Thai Revenue Department issued instructions to revise the tax treatment of foreign income remitted into the country by individual taxpayers, effective from January 1 2024.

Revenue Department instructions No. Paw 161 and Paw 162 state that a tax resident of Thailand who derives assessable income from an employment or business carried on abroad, or from a property situated abroad, shall be required to include such income in their personal income tax return for the payment of tax in the year that the income is brought into Thailand.

The instructions were issued by the Revenue Department as guidelines to revenue officers when conducting tax audits or advising taxpayers on the taxation of foreign income under the Revenue Code. The law remains unchanged. Prior to the Revenue Department issuing these two instructions, the law had been interpreted as limiting the taxation of foreign income to income that is derived and remitted into Thailand in the same tax year.

Foreign income earned in 2023 or prior years that is brought into Thailand after December 31 2023 will not be subject to tax.

Guidance from the Revenue Department

It will be important for taxpayers remitting funds from offshore into Thailand to consider how they determine if the funds are taxable or not.

The Revenue Department has issued a Q&A on the taxation of foreign income to help taxpayers to understand the implications of the changes. Similar to other countries with remittance rules, the Revenue Department will likely need to clarify further what constitutes a remittance.

The Revenue Department has announced that it will commence discussions with stakeholders on improving the methods for collecting personal income tax on income from sources outside the country. In this regard, Thailand has implemented the Common Reporting Standard, an internationally agreed standard for the automatic exchange of financial account information between jurisdictions for tax purposes, to better combat tax evasion and ensure tax compliance.

Double taxation relief

Thailand has double tax agreements with over 60 jurisdictions, which can modify the tax treatment under the Revenue Code; e.g., by granting taxing rights to the other country only or allowing a credit for tax paid in the other country against the tax payable in Thailand. The credit will be granted if the foreign tax is paid in accordance with the provisions of the double tax agreement and will in general be limited to the Thai tax payable on the income.

Interestingly, the Revenue Code does not contain provisions to grant personal income taxpayers a unilateral foreign tax credit in the case where the income is from a country that does not have a double tax agreement with Thailand.

Tax exemption for LTR visa holders

Approximately a year before the Revenue Department announced the changes to foreign income taxation, Thailand launched a long-term resident visa (LTR visa) programme to enhance the country’s attractiveness as a regional hub for living and doing business for ‘high-potential’ foreigners.

One of the benefits granted to an LTR visa holder is an exemption from income tax on foreign income brought into Thailand, pursuant to Royal Decree No. 743 issued under the Revenue Code. The exemption applies to income from an employment or from business carried on abroad, or from a property situated abroad, that has been brought into Thailand.

There are three categories of LTR visa holders eligible for the exemption:

  • Wealthy global citizens;

  • Wealthy pensioners; and

  • Work-from-Thailand professionals.

Foreign nationals holding an LTR visa in one of these categories are not affected by the change of the Revenue Department’s interpretation of the law.

more across site & shared bottom lb ros

More from across our site

If the US doesn't participate in pillar two then global consensus on the project can’t be a reality, tax academic René Matteotti also suggests
If it gets pillar two right, India may be the ideal country that finds a balance between its global commitments and its national interests, Sameer Sharma argues
As World Tax unveils its much-anticipated rankings for 2026, we focus on EMEA’s top performers in the first of three regional analyses
Firms are spending serious money to expand their tax advisory practices internationally – this proves that the tax practice is no mere sideshow
The controversial deal would ‘preserve the gains achieved under pillar two’, the OECD said; in other news, HMRC outlined its approach to dealing with ‘harmful’ tax advisers
Former EY and Deloitte tax specialists will staff the new operation, which provides the firm with new offices in Tokyo and Osaka
TP is a growing priority for West and Central African tax authorities, writes Winnie Maliko, but enforcement remains inconsistent, and data limitations persist
The UK tax agency has appointed six independent industry specialists to the panel
The two tax partners have significant experience and expertise in transactional and tax structuring matters
Katie Leah’s arrival marks a significant step in Skadden’s ambition to build a specialised, 10-partner London tax team by 2030, the firm’s European tax head tells ITR
Gift this article