Tax
Hi everyone,
I’m looking for clarification from anyone with professional knowledge or direct experience of Thai personal income tax and remote employment.
Hypothetical situation:
-Living in Thailand on a DTV visa
-Staying in Thailand for 180 days or more and therefore becoming a Thai tax resident
-Working remotely for a Danish employer
-Advising and selling insurance exclusively to customers in Denmark
-Receiving the salary into a bank account outside Thailand
-Having no Thai employer, customers, clients or commercial activity
Would the salary be classified as foreign-sourced income or Thai-sourced income for Thai personal income tax purposes?
My specific concern is Section 41 of the Thai Revenue Code. Does physically performing the remote work while located in Thailand make the salary Thai-sourced, even though the employer, customers, market, contracts, salary payment and bank account are all outside Thailand?
The position is entirely connected to the Danish insurance market and requires specialist knowledge of Danish insurance products, regulations and customer advisory practices. No services are provided to Thailand or the Thai market.
I’m specifically interested in the legal tax classification—not simply whether this type of remote work is permitted under the DTV visa. If possible, please include relevant Thai Revenue Department guidance, rulings or other legal sources supporting your answer.
Thank you.