Personal income tax on Thai vs foreign-sourced income.

Thailand taxes individuals based on both their residency status and the source of their income. For tax residents, foreign-sourced income brought into Thailand is subject to personal income tax (PIT). The rules governing what qualifies as income ‘remitted to Thailand’, as well as when the related tax liability arises, were significantly revised with effect from 1 January 2024.

This guide explains the difference between Thai-sourced and foreign-sourced income, how the 2024 rule change works in practice, what remittance means under Thai tax law and how the rules differ for individuals versus Thai-incorporated companies.

What is personal income tax?

Personal income tax is a legal obligation that applies to all individuals (non-juristic persons) in Thailand. It is levied on assessable income, which the Thai Revenue Code divides into eight categories, including employment income, business profits, rental income, dividends, interest and capital gains.

The rate structure is progressive, with rates ranging from 0% on the first THB 150,000 of net income to 35% on net income above THB 5 million. Thailand’s wider tax framework covers the main categories and how they interact.

Taxpayers in Thailand are classified as residents or non-residents. Residents are taxed on both Thai-sourced and foreign-sourced income. Non-residents are taxed on Thai-sourced income only.

Thai-sourced income

Regardless of nationality, Thailand will impose personal income tax on income that is generated from Thai sources. Any income created as a result of an activity taking place in Thailand is deemed taxable in Thailand in the same calendar year it is received, regardless of where it is paid and the recipient’s tax residence status.

What counts as Thai-sourced income?

Income is considered as Thai-sourced income if it is derived from:

• Work performed in Thailand
• A business carried on in Thailand
• A business of an employer based in Thailand
• Property located in Thailand

The key principle is that the activity or asset generating the income must be situated in Thailand. Where payment is received overseas for work performed in Thailand, the income remains Thai-sourced and taxable in Thailand.

Foreign-sourced income

Foreign-sourced income follows the same categories as Thai-sourced income, but the underlying activity or asset is located outside Thailand. A salary from a foreign employer for work performed abroad, dividends from an overseas company or rental income from a property in another country are all examples of foreign-sourced income.

For non-residents, foreign-sourced income is not subject to Thai personal income tax. For residents, it is taxable when it is brought into Thailand, subject to the rules described below.

An individual is a Thai tax resident if they are present in Thailand for 180 days or more during a calendar year, whether consecutively or in aggregate.

The current rule on foreign-sourced income

Under Departmental Instruction No. Por. 161/2566, which took effect on 1 January 2024, foreign-sourced income earned by a Thai tax resident is taxable in the year it is remitted to Thailand, regardless of when it was originally earned. One exception applies: income earned before 1 January 2024 remains exempt from Thai personal income tax even if remitted now, under the clarification issued in Por. 162/2566.

The following scenarios illustrate how the rules apply in practice:

Scenario A: Pre-2024 income remitted after the rule change

A Thai tax resident earned consulting income from an overseas client in 2022 and kept the funds in a foreign bank account. In March 2025 they transfer the funds to a Thai bank account. Because the income was earned before 1 January 2024, it is not subject to Thai personal income tax regardless of when it enters Thailand.

Scenario B: Post-2024 income remitted in a later year

A Thai tax resident earned dividends from a foreign investment portfolio throughout 2024 and left the funds offshore. In February 2026 they transferred the dividends to a Thai bank account. Because the income was earned on or after 1 January 2024, it is assessable in 2026, the year of remittance, and personal income tax applies.

Scenario C: Mixed funds

A Thai tax resident holds a foreign bank account that contains savings accumulated before 2024 as well as investment returns earned in 2024. They transferred a single amount to Thailand in 2025. The pre-2024 portion is exempt. The post-2024 income may be taxable. The Revenue Department applies a first-in, first-out (FIFO) approach where funds are mixed and cannot be clearly traced, which places the documentation burden on the taxpayer. Keeping pre-2024 savings in a separate account from post-2024 income is the clearest way to avoid an adverse outcome.

Proposed two-year remittance exemption

The current rules under Por. 161 are under review. The Thai Revenue Department has proposed an amendment that would exempt foreign-sourced income from Thai personal income tax if remitted to Thailand within the same calendar year it was earned or within the following calendar year. Income remitted beyond that two-year window would remain taxable under the standard progressive rates. For example, under the proposed rule, income earned in a given year and brought into Thailand at any point during that year or the next would not be subject to Thai personal income tax.

The amendment has not been formally enacted and requires Cabinet approval and Council of State review before becoming law. Until the decree is published in the Royal Gazette, Por. 161 continues to apply. Updates regarding foreign-sourced income exemptions are published on the Revenue Department website.

How income is considered remitted into Thailand

The Revenue Department defines “brought into Thailand” as any action that moves foreign-sourced income into Thailand for use, including the following:

• Wire transfers or e-banking transfers from a foreign account to a Thai bank account
• ATM withdrawals in Thailand using a foreign bank card, where the funds are sourced from foreign income
• Debit or credit card spending in Thailand charged against a foreign account holding foreign-sourced income
• Physical cash carried into Thailand where the cash represents post-2024 foreign-sourced income

Unrealised gains on overseas investments are not taxable. Tax arises only when a gain is realised and the proceeds are subsequently brought into Thailand.

Where a single transfer contains both pre-2024 exempt funds and post-2024 taxable income, clear records identifying the composition of the remittance are essential. Without documentation, the Revenue Department may assess the full amount.

Individuals versus Thai-incorporated companies

The remittance-based rules described in this guide apply to individuals subject to personal income tax. The position is different for those who operate through a Thai-registered company rather than as an individual or sole trader.

Thai-incorporated companies are subject to corporate income tax on their worldwide net profit in the year it is earned, regardless of whether funds are transferred into Thailand. This means a Thai company that invoices overseas clients or earns income from foreign sources has a tax liability arising in the accounting year the income accrues, with no equivalent remittance concept. An individual tax resident, by contrast, can hold foreign income offshore without Thai personal income tax arising until the funds enter Thailand.

This distinction matters for freelancers, consultants and business owners choosing how to structure their work. Operating through a Thai company brings foreign income into the corporate tax net immediately, while an individual operating in their own name is taxed on remittance timing. Neither structure is inherently preferable and the right approach depends on the nature of the income, the volume of overseas revenue and other commercial factors.

For the full picture on rates, filing obligations and how foreign-sourced income is treated at the corporate level, the corporate income tax in Thailand guide covers these in detail.

Double tax agreements and foreign tax credits

Thailand has concluded double tax agreements (DTAs) with more than 60 countries. Where a DTA applies, it may reduce or remove the Thai personal income tax obligation on certain categories of foreign-sourced income and generally allows foreign tax paid to be credited against Thai tax.

For the full list of countries and treaty protocols, see the Revenue Department’s DTA page. Residents claiming a foreign tax credit should retain official tax certificates from the foreign jurisdiction, as documentation is required to support the claim.

Long-Term Resident visa exemption

Thailand’s Long-Term Resident (LTR) visa is available to qualifying wealthy individuals, retirees, highly skilled professionals and remote workers. Certain LTR visa holders are granted an exemption from Thai personal income tax on foreign-sourced income, which is not subject to the remittance timing rules under Por. 161.

Individuals considering the LTR visa as a tax planning measure should confirm which sub-category they qualify for, as the tax benefit differs across categories. The Thai Board of Investment’s LTR visa page provides current eligibility criteria and application requirements.

Conclusion

The main distinction in Thailand’s personal income tax system is that Thai-sourced income is taxable for all individuals regardless of residency, while foreign-sourced income is taxable for residents only when it enters Thailand. The 2024 rule change means income earned from 1 January 2024 onward is taxable in the year it is remitted, not the year it was earned.

For individuals planning remittances, the key considerations are whether income was earned before or after 1 January 2024, how funds are held and documented, and whether a DTA or LTR visa exemption applies. Residents should monitor the Revenue Department announcements for updates on the proposed remittance exemption before making decisions based on it.

How Acclime can help with personal income tax on foreign-sourced income in Thailand

Acclime provides personal income tax advisory and compliance support for residents and non-residents with foreign-sourced income. Our team can advise on the tax treatment of remittances under the current rules, review the application of double tax agreements to your income types and help you maintain the documentation needed to support your tax position. Contact Acclime to discuss your situation and confirm the most practical approach for your income and residency profile.