Mazars Payroll Flash news - September 2023

Currently, foreign-sourced income which foreigners who are Thai tax residents bring into Thailand in a tax year other than that in which the income is earned is exempt from Thai tax.

An individual who is physically present in Thailand for one or more periods totalling more than 180 days in a calendar year are considered Thai tax residents.

Foreign-sourced income is income derived from a location outside of Thailand, such as from work, interest earned on savings accounts abroad, dividends, and capital gains made on foreign stocks.

However, on 15 September 2023, the Director-General of the Revenue Department published Revenue Departmental Instruction No. Paw. 161/2566 regarding income tax under Section 41, paragraph 2, of the Revenue Code.

This Departmental Instruction states that, from 1 January 2024, foreign-sourced income of foreigners who are Thai tax residents will be treated as assessable income and subject to tax in Thailand in whichever tax year the income is brought into Thailand.  

Source (in Thai):

Revenue Departmental Instruction No. Paw. 161/2566