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Thailand: new order closes tax loophole for offshore-sourced income

On September 15, Revenue Departmental Order No. Por. 161/2566 was published, fundamentally changing how Thailand tax residents’ offshore-sourced income will be taxed.

Under the order, starting from January 1, 2024, the offshore-sourced income of tax residents will be subject to Thai personal income tax (PIT) in any year that it is brought into Thailand. The purpose of this new rule is to ensure consistent tax collection practices among tax officers and to tackle tax avoidance strategies commonly used by individual taxpayers.

PIT on Offshore-Sourced Income

According to the resident rule in Thailand’s Revenue Code, Thailand tax residents (i.e., persons who reside in Thailand for at least 180 days in a calendar year) are subject to PIT on their domestic-sourced and offshore-sourced income. “Offshore-sourced income” is broadly defined to include income from work, business, or…

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