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November 23, 2023

Thailand: Prior Income Exempt from New Rule on Offshore-Sourced Income

Thailand’s Revenue Department has issued an order clarifying its recent order imposing personal income tax (PIT) on the offshore-sourced income of Thailand tax residents whenever it is brought into Thailand.

The clarifying order, which was issued on November 20, 2023, confirms that the new rule will not apply to offshore-sourced income earned before January 1, 2024, which is the date the order comes into effect. This means that offshore-sourced income earned before January 1, 2024, will not be subject to PIT if it is brought into Thailand after the year 2023.

This grandfather protection means that Thai tax residents will not have to pay PIT on offshore-sourced income earned before 2024 and brought into Thailand at any time after 2023. This is favorable to many who have earned income from offshore sources but may not have had sufficient time to revise their tax planning in response to the new rule.

For more details on Thailand’s taxation of tax residents’ offshore-sourced income, or on any aspect of tax laws and regulations in Thailand, please contact Tilleke & Gibbins at [email protected].

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