Thailand: Further guidance on foreign-sourced income brought into Thailand by Thai tax residents
Departmental Instruction No. Por 162/2566
Departmental Instruction No. Por 162/2566
The Thai Revenue Department on 20 November 2023 issued further guidance—Departmental Instruction No. Por 162/2566—regarding the individual (personal) income tax implications for foreign-sourced income brought into Thailand by Thai tax residents.
Previous guidance was issued providing an interpretation of Section 41 Paragraph 2 that any foreign-sourced income brought into Thailand from 1 January 2024 onwards will be subject to Thai individual income tax, regardless of the tax year in which the income was derived. Read TaxNewsFlash
The new guidance clarifies that the interpretation provided in Clause 1 of DI No. 161/2566 does not apply to foreign-sourced income derived before 1 January 2024.
KPMG observation
The foreign-sourced income derived by a Thai tax resident before 1 January 2024 may be subject to the previous interpretation (i.e., said income would not be subject to Thai individual income tax unless it is brought into Thailand in the same year in which the income is derived). This could ease the burden on taxpayers planning the remittance into Thailand of foreign-sourced income that had already been derived prior to the issuance of Departmental Instruction No. Por 162/2566.
Read a December 2023 report prepared by the KPMG member firm in Thailand
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