Thailand | Employment Tax | PAW 162—Further update on taxation of offshore source income in Thailand

24 November 2023

Personal Income Tax

Thailand | Employment Tax | PAW 162 – Further update on taxation of offshore source income in Thailand

Impact: High

Summary
The Revenue Departmental Instruction No. Paw 162/2566 was issued on 20 November 2023 which is a further guidance on the Departmental Instruction No. Paw 161/2566 issued on 15 September 2023. The Thai Revenue Department (TRD) has further updated its stance on how it will tax offshore source income, as below.

Current regulations	Paw 161/2023 & Paw 162/2023 New guidelines on 15 September and 20 November 2023
Thailand has not taxed its tax residents on their worldwide income. If income earned outside Thailand arising from non-Thai employment, business carried on abroad, or from a property situated abroad, was not remitted into Thailand in the same year that it was earned, that income was exempt from Thai tax. This allowed Thai tax residents to plan ahead so that their offshore income was tax free in Thailand. Remark: A resident of Thailand, i.e., one who resides in Thailand for 180 days or more in the calendar year.	A resident of Thailand must include the amount that is remitted to Thailand in their personal income tax return, regardless of when such income is remitted into Thailand. This instruction is effective for any offshore source income remitted into Thailand from January 1, 2024, onwards but shall not apply to assessable income earned before 1 January 2024. (updated by Paw 162/2566)
Paw 162/2566: This instruction is positive for individuals who are Thai tax residents deriving income from abroad as they can still remit such income earned before 1 January 2024 into Thailand in the following years tax free. Important note: Thai resident individuals who have offshore source income from 1 January 2024 onwards should still prepare all the supporting documents and transaction details for tax purposes.

Changes in tax interpretation could impact your net take-home. We will keep you posted since more guidelines from the TRD are expected.

Contact Us
For a deeper discussion on the above, please reach out to your Vialto Partners point of contact, or alternatively:

Jiraporn Chongkamanont
Partner
jiraporn.chongkamanont@vialto.com

Napaporn Saralaksana
Associate Director
napaporn.saralaksana@vialto.com

Natchanond Charoenmechaikul
Senior Manager
natchanond.charoenmechaikul@vialto.com

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