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Thailand Proposes Tax Exemption to Repatriate 2 Trillion Baht in Overseas Assets

The Thai tax proposal lets wealthy residents bring foreign earnings home tax-free if repatriated within two years of generation.

The Thai tax proposal lets wealthy residents bring foreign earnings home tax-free if repatriated within two years of generation.

Thailand’s Revenue Department has proposed amending ministerial regulations to offer tax exemptions on foreign-sourced income, targeting over 2 trillion baht ($58.8 billion) in overseas Thai investments. The proposal allows income earned and repatriated within two tax years to be exempt from personal income tax, extending similar benefits already available to certain Long-Term Resident visa holders.

Current Revenue Performance and Targets

The Revenue Department collected 1,138,182 million baht ($33.5 billion) in the first seven months of the current fiscal year (October 2024 – April 2025), exceeding last year’s figures. However, the department anticipates a decline between May and July, with year-end corporate income tax filings expected to fall short by over 15 billion baht ($441 million).

The government has set a target of 2.4 trillion baht ($70.6 billion) for fiscal year 2026, an increase of over 100 billion baht ($2.9 billion) from 2025’s target. The Fiscal Policy Office earlier estimated a potential 36 billion baht ($1.1 billion) shortfall for the entire fiscal year.

To bolster revenue, the Revenue Department plans proactive audits of businesses not currently in the tax system, focusing on restaurants, nightlife venues, cash-based trade, and pharmacies. The department is also exploring policy adjustments, such as potentially increasing the Value Added Tax rate from 7%, along with administrative improvements and structural changes for new revenue-generating taxes.

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Proposal Details

Revenue Department Director-General Pinsai Suraswadi revealed that the department is reviewing changes to rules on foreign income brought into Thailand. The department has identified over 2 trillion baht ($58.8 billion) in Thai investments abroad, spanning assets from real estate to stocks, generating hundreds of billions in returns.

The proposal represents a shift from the stricter rules Thailand implemented in January 2024. Thailand’s tax system generally levies personal income tax on foreign earnings brought into the country, with the January 2024 adjustment applying from that date onwards. Revenue Department officials acknowledge that the 2024 rules discouraged many individuals from remitting foreign earnings, limiting capital inflows into the Thai economy.

Under the new proposal, Thailand would exempt foreign income generated from 2024 onwards if individuals repatriate it within two tax years from its origin. Thailand would tax income brought in after this period normally. For concerns about double taxation, Thailand maintains a tax credit mechanism under its agreements with 61 countries, allowing taxpayers to offset foreign tax paid against their Thai liability.

Legislative Process Requirements

The proposal must complete a multi-stage approval process before becoming law. After the principal approval by the Council of Ministers, the Council of Ministers will send the bill to the Office of the Council of State for technical examination by specialized law committees.

Following examination, the bill returns to the Council of Ministers for final approval on text before introduction to the National Assembly. The National Assembly will consider the bill through three readings according to constitutional convention. Upon National Assembly consent, the National Assembly will submit the bill to the King for Royal Signature and publication in the Government Gazette.

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Pinsai confirmed that “the process will involve Cabinet approval and a review by the Council of State before becoming law.” Officials are finalizing the exact legal mechanism—either a royal decree or ministerial regulation.

Thai Council of Ministers

Implications for High Net Worth Individuals

The proposed tax exemption primarily targets wealthy Thai nationals and tax residents who have moved assets offshore. The policy affects individuals who maintain investments in foreign real estate, international stock portfolios, overseas business ventures, and foreign bank deposits generating income abroad.

Under the current system, Thai tax residents must pay personal income tax on foreign-sourced income when brought into Thailand. The proposed two-year exemption window allows these individuals to repatriate earnings without immediate tax consequences, provided they act within the specified timeframe.

The policy creates a limited-time opportunity for wealthy Thais to restructure their international holdings. Those with substantial foreign investments generating regular income streams could potentially bring years of accumulated earnings back to Thailand tax-free, subject to the two-year rule.

However, the exemption only applies to income generated from 2024 onwards. Pre-2024 earnings would face existing tax obligations under previous regulations. The policy also requires that Thailand maintains its tax credit agreements with 61 countries to prevent double taxation issues.

Thailand has been actively courting wealthy individuals through various programs, including the Long-Term Resident visa Thailand launched in September 2022, which has issued 6,000 visas over two years. The government recently eased Long-Term-Residency (LTR) program requirements, removing the $80,000 annual income requirement for “Wealthy Global Citizens” category applicants in January 2025.

For LTR visa holders, the proposal creates an interesting dynamic. LTR holders in the “Wealthy Investor,” “Wealthy Retiree,” and “Work-from-Thailand Professionals” categories already maintain exemption from personal income tax on offshore income repatriated to Thailand the year after earning it overseas. The new proposal essentially extends similar benefits to all Thai tax residents but with a more restrictive two-year window.

LTR holders may find their existing tax advantages remain more favorable than the general repatriation proposal, particularly for income streams that can be timed for repatriation in subsequent years. Those in the “Highly Skilled Professionals” category, who pay a flat 17% personal income tax rate, could potentially benefit from the new exemption for qualifying foreign income.

For expatriate tax residents in Thailand, the exemption should apply equally under Thailand’s principle of non-discrimination in tax law, though specific implementation details remain pending final legislative approval.

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