Thailand Taxes Foreign-Sourced Income for 180-Day-Plus Foreign Residents from 2024
Starting 1 January 2024, Thailand imposes income tax on foreign-sourced income remitted into Thailand by foreigners who stay 180 days or more in a calendar year. Foreigners meeting this residency threshold must report both Thai-sourced and foreign-sourced income (when remitted) on Personal Income Tax Returns P.N.D.90 or P.N.D.91. Income tax paid abroad may be credited against Thai taxes under applicable Double Tax Agreements, with credit limited to the Thai tax attributable to the foreign income. Foreigners staying fewer than 180 days or earning foreign income before 1 January 2024 remain outside this tax scope.
Thailand Emergency Decree on Top-up Tax B.E. 2567 Takes Effect January 2025
Thailand's Emergency Decree on Top-up Tax, B.E. 2567 (2024), was promulgated in the Royal Gazette on 26 December 2024 and takes effect for accounting periods commencing on or after 1 January 2025. The decree applies to large MNEs with consolidated financial statement revenues of at least €750 million and establishes a globally-aligned minimum tax floor in line with the OECD Pillar Two framework. The Revenue Department will propose secondary legislation and implement electronic systems for GloBE Information Return submissions. By 2024, 28 countries including Vietnam, Germany, France, and the UK have enacted similar laws, with Malaysia, Singapore, Indonesia, and Hong Kong expected to follow in 2025.
Thailand Cabinet Approves Four Draft Top-up Tax Instruments
Thailand's Cabinet approved four draft secondary legislation instruments under the Emergency Decree on the Top-up Tax B.E. 2567 (2024) at its meeting on 30 December 2025. The instruments cover: criteria for MNE groups after organisational restructuring; criteria for entities not qualifying as constituent entities; criteria for allocating Top-up Tax under the UTPR mechanism when no Thai constituent entity has GloBE income; and criteria for adjusting income, expenses, and covered taxes for Top-up Tax calculation. The drafts align with OECD GloBE Model Rules and apply to large MNE groups for accounting periods commencing on or after 1 January 2025.