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Grant Thornton Thailand is a professional international audit firm with expertise and experience. We provide a high quality, world-class independent audit...

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Grant Thornton Thailand is a professional international audit firm with expertise and experience. We provide a high quality, world-class independent audit...

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In today's increasingly competitive and regulated market place, organisations - both public and private - must demonstrate that they have adequate controls and safeguards in place. The availability of qualified internal audit resources is a common challenge for many organisations.
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Related insights:

Executive Talent Executive talent makes all the difference

We’ve all seen it: Companies coasting on past successes, telling themselves that they’ll start to push ahead in earnest once the economy gets better, and treading water in the meantime by focusing on modest incremental improvements in the products and services of which they used to be pioneers. They will have their reasons, and most will sound perfectly sensible when expressed and explained. But businesses should be extremely wary of all attempts to rationalise inaction, or deliver excuses rather than results. If an organisation’s key obstacles are not being aggressively addressed, the deeper problem is usually a lack of internal direction or urgency. Both of these are failures of leadership.

Charasporn Uppawong

| 4 min read | 28 Apr 2024

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Dynamic organisations need a broad range of advisory services to support their ambitions and growth. Our advisory services are designed to help you achieve...

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Valuations-migrated
Valuations

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Dynamic organisations need a broad range of advisory services to support their ambitions and growth. Our advisory services are designed to help you achieve...

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Japanese Business Practice (日系企業の皆様へ), 税務・法務, ビジネス・プロセス・ソリューション, 通訳・翻訳, アドバイザリーサービス, 監査・保証業務, エグゼクティブリクルート（ヘッドハンティング）.

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In the dynamic world with unprecedented events, it is imperative that organizations balance their risks, controls while capturing the opportunities in order to...

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Consumer products

Emerging markets and shifting consumer demand are creating new opportunities in this industry, with business leaders investing in new products, markets and...

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IBR Optimism of Thailand Mid-Market Leaders Suggests Potential Underestimation of Challenges Ahead: International Business Report, Q1 2024
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2 min read | 10 Apr 2024
Workshop Corporate Strategy and Company Health Check Workshop
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1 min read | 19 Mar 2024
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1 min read | 08 Jan 2024
TAX AND LEGAL Complying with the PDPA – A Balancing Act
Organisations must be aware of the circumstances in which they are allowed to collect data to comply with Thailand’s Personal Data Protection Act.

Tanva Mahitivanichcha
| 06 Mar 2020

Energy & resources

Energy markets worldwide are undergoing major changes. Grant Thornton can help you understand and navigate the challenges, and make sure you have the solutions...

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Financial services

Financial services firms operate under complex and heavy regulation. Grant Thornton’s global network of member firms assists clients with asset management,...

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Healthcare

Healthcare is a rapidly changing sector. Providers and commissioners of healthcare face the challenges of rising public expectations, an ageing population,...

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Across the globe, not for profit organisations are increasingly expected to deliver more, while at the same time facing cuts in government funding and...

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While the impact of the prolonged downturn continues to be felt, pockets of opportunity and optimism have emerged within the retail estate and construction...

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Technology, media & telecommunications

Rapid change and complexity are norms, and innovation the fuel in the technology industry. Today’s revolutions – including cloud, as-a-service, social media...

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Travel, tourism & leisure

The travel, tourism and leisure industry is undergoing dramatic change: consumers are now calling the shots. Grant Thornton’s global network of industry...

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Tax & Legal

Tax Alert: Proposed Adoption of New Overseas Income Rules

By:

Tanva Mahitivanichcha,

Sanporn Sanpatchaya

21 Jun 20242 min read

Contents

Last year, the Thai Revenue Department (“TRD”) issued Departmental Instructions No. Paw 161/2023 and Paw 162/2023 concerning foreign-sourced income. According to these instructions, any Thai tax resident with foreign-sourced income will be taxed in Thailand when such income is remitted into the country, regardless of when you remit it (please see the links below for more details):

Grant Thornton Tax Alert 1
Grant Thornton Tax Alert 2

It still isn’t clear, though, how the recipient will be able to receive credit for foreign taxes paid on such income under applicable Double Tax Treaties or otherwise.

Recently, the TRD announced in a newspaper[1] that they are preparing to amend the law to adopt a new rule to impose personal income tax on all worldwide income accrued by Thai taxpayers. This new rule would allow the TRD to collect tax from any Thai tax resident who derives foreign-sourced income, even if they do not bring such income into Thailand. However, this proposed new rule is still under discussion. We will keep you updated as more information becomes available.

Who Will Be Affected by This New Rule?

The proposed new rule will affect both foreigners working in Thailand for more than 180 days and Thai citizens who are Thai tax residents working abroad. A key question is whether this new rule will affect Long-Term Resident (LTR) Visa holders. The answer is: “It Depends”.

Currently, the interpretation is issued as a guideline. The LTR rules will prevail based on the hierarchy of laws and the principle of lex specialis. However, if the TRD chooses to amend the Thai Revenue Code, the new rule will likely take precedence. Nonetheless, the government is unlikely to do this, as the LTR is designed to benefit LTR holders.

As mentioned, the TRD is still reviewing and studying the potential impact of this new rule. We will monitor the situation closely and keep you informed of any developments.

[1] https://www.bangkokpost.com/business/general/2805305/new-overseas-income-rules-proposed

Tax Alert: Proposed Adoption of New Overseas Income Rules

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