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Thai "Income Tax Consequences for Tax Residents"?

Transcript of the above video:

As the title of this video suggests, we are discussing Income Tax consequences for tax residents in Thailand. I thought of making this video after reading a recent article from the Pattaya Mail, that is pattayamail.com, the article is titled: Foreigners and Thai Law: the changing Pattaya scenario. Quoting directly: "Another growth area will almost certainly be the income tax consequences for tax residents." Well first and again I'm not trying to nitpick anybody here but we are talking about fine points of Thai Tax Law here. It may not necessarily be income tax. There are other types of tax, capital gains tax, withholding tax, all sorts of things here in Thailand. Specific Business tax, Transfer taxes associated with property but again they keep talking about it like it's an income tax. Again it may or may not be, but these are terms of art; they have specific meaning and again they're used, and again I'm not calling anybody out exactly on this because when you are talking in like a forum, in like a newspaper or something, you are going to have  sort of an off-the-cuff element to your discussion, I get that but when you are talking about something as precise as tax, that's probably not the best way to sort of approach it I guess I would say.

In any event, quoting again: "Another growth area will almost certainly be the income tax consequences for tax residents, Thai or foreign, who spend 180 days or more in Thailand over a calendar year and remit cash from abroad." Now that is a really important point. The remittance of cash from abroad and the nature of that emittance will drive the analysis regarding tax assessability and liability. Quoting further: "Our understanding is that the Thai Revenue Department will be publishing forms and a commentary later in the year." I haven't seen anything to support the fact that that is a foregone conclusion. I have seen some implication of that like if you are reading between the lines, there is some element of truth in that but I am not operating from the presumption that we are going to see a change in the actual stipulated rules from the Revenue Department. That said, quoting further: "Hopefully this covers contentious issues such as double taxation treaties and pensioners living here on pre-tax income." You know I would not hold my breath for that. Why? Because that's not the way Tax Law works. They're not going to be able to, well they may, who knows. I don't know what they're doing but I find it very unlikely that they're going to be able to issue a sort of one size fits all primer to how Thai Tax Law is going to be applied in all situations, to all foreigners. They brought up double taxation treaties; there are dozens if not hundreds of those. You are going to be able to come up with a unified set of rules that encompasses all of that? No very unlikely. At the end, again it's not a foregone conclusion they're going to issue any major rule changes at all; they could just leave it as it is. And look I remember dealing with the raw law coming off of Trump Tax going back into the first Trump Administration when that came down the pike and what was that, the Tax Cuts and Jobs Act, or whatever, it was colloquially referred to as Trump Tax. In any event, yeah I remember seeing the raw law on that and like it hardly made any sense; it took forever to wade through all of that. I remember other folks out there in the world when they were analyzing that stuff, I mean some people had one take on it, others had another. It takes a while to shake out and then the regulatory structure gets put into place. Again the notion that there is going to be like a one size fits all primer for all of this, I just don't think that that's very likely.