Thailand Cross-Border Tax Guide

180-Day Rule — Tax Residency

• Residence threshold — 180 days: An individual is considered a Thai tax resident if present in Thailand for 180 days or more in a calendar year (the "tax year" in Thailand is the calendar year — January 1 to December 31). The days of entry and exit both count as the days of presence.
• Consequences of residency: The resident is taxable on: (a) all the Thai-source income regardless of remittance, (b) all the foreign-source income if remitted to Thailand (and from 2024 onward, the foreign-source income is taxable regardless of remittance). See the Tax Residency Guide for the full details.

Source Rules

• Thai-source income: The income derived from the employment performed in Thailand, the business carried on in Thailand, or the assets located in Thailand is the Thai-source income. The examples: the salary for the work done in Thailand, the rental income from the Thai property, the dividends from the Thai companies, the capital gains from the sale of the Thai assets.
• Foreign-source income (Post-2024): From the 2024 tax year onward, the Thai tax resident is taxable on the foreign-source income regardless of whether it is remitted to Thailand. Previously (before 2024), the foreign-source income was taxable only if brought into Thailand within the same tax year. The Revenue Department's announcement in 2023 (the "RD Order No. Por 161/2566") confirmed the change — the foreign income earned from 2024 onward is subject to the PIT upon the receipt, irrespective of the remittance.
• Transitional rule: The foreign-source income earned before 2024 and remitted to Thailand after 2023 may still be taxable under the old rules — the remittance in a later year triggered the tax liability. The taxpayers should review the specific facts and the Revenue Department's guidance.

Double Tax Agreement (DTA) Network — 60+ Treaties

Thailand has signed the double tax agreements (DTAs) with 60+ countries and jurisdictions, including the US, the UK, Japan, China, Australia, Germany, France, Singapore, Malaysia, Vietnam, and most of the major economies. The DTAs allocate the taxing rights between Thailand and the treaty partner and provide the relief from the double taxation. The key provisions include: the permanent establishment threshold (more than 180 days for the services), the reduced withholding tax rates on the dividends (10% to 15%), the interest (10% to 15%), and the royalties (5% to 15%).

Foreign Tax Credit (FTC)

• Mechanism: The Thai resident who pays the foreign tax on the foreign-source income may claim the foreign tax credit against the Thai PIT liability on the same income. The credit is limited to the lower of: (a) the foreign tax paid, or (b) the Thai tax attributable to the foreign income (the "per-country limitation").
• Computation: The FTC is calculated as: (the foreign-source income ÷ the total assessable income) × the total Thai tax liability. The unused foreign tax credit may be carried forward for up to 3 years.
• Treaty relief vs FTC: If the DTA provides the exemption (the "tax sparing" or the "exemption method"), the foreign income may be exempt from the Thai tax entirely. The taxpayer may choose between the treaty exemption and the FTC — whichever is more beneficial.

FAQs

Is the foreign pension taxable in Thailand?

Under most DTAs, the foreign pension is taxable only in the country of the residence (Thailand) unless the pension is paid by the government (the "government service" pensions may be taxable only in the source country). The Thai resident receiving the foreign private pension must declare it in the PIT return.

Do the foreign bank accounts need to be reported?

Thailand does not have the specific foreign account reporting requirement (like the FBAR in the US) for the individuals. However, the income earned in the foreign accounts must be declared in the PIT return if it is the foreign-source income taxable from 2024 onward.