In brief
On 15 September 2023, the Director General of the Revenue Department issued the Revenue Departmental Order No. Por. 161/2566 re: Income Taxation under section 41, paragraph two of the Revenue Code (“New Order“). This New Order will require Thai tax resident individuals who bring offshore-sourced income (i.e., income from work or business carried on outside Thailand or income from property situated outside Thailand) into Thailand from 1 January 2024 onward to be subject to Thai personal income tax, regardless of whether such income is brought into Thailand in the same calendar year of receipt or in subsequent years.
In more detail
Current interpretation
According to paragraph two of section 41 of the Revenue Code, Thai tax resident individuals, i.e., any person who stays in Thailand for at least 180 days in any calendar year, shall pay Thai personal income tax on the…