@Andy ***********
Maybe you need to either follow a course how to write what you want to write, or a course how to read what you wrote.
You clearly stated “It’s Thai citizens who are being targeted, not expat retirees, who remain non-taxable.”
There are too many mistakes in this statement. First of all it’s completely irrelevant whom the rules change targets. It might be targeted at polar bears, but as soon as penguins fall under the same criteria the law applies to them too. Whether they are polar bears or not.
1) The law might not target expats, but as soon as they are within the criteria set by the law, which quite likely includes every expat in Thailand, they are within the boundaries of the tax laws.
2) Expats remain non-taxable. It’s a funny thought because this seems to imply that expats were ever no -taxable. Not true. Since the law was created, I believe in previous century, expats are just as taxable as anyone else as soon as they reach the 180-days-in-Thailand limit. There are rules which parts of their income was taxable and there are treaties on a per country basis which reduce the tax load on some nationals. However, if you check the list you would soon find out that there are no DTAs with both the North Pole and Antarctica, meaning that both polar bears as well as penguins will become taxable as soon as they stay here 180 days in a calendar year (provided they declare themselves human beings).
There indeed is (almost) nothing new here. Expat retirees were always taxable but could reduce their ass-essable income by lifting their income transfer over the year end. But this has changed. Since
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/2024 only savings as per 31 dec 2023 can be taxfree brought to Thailand.
For new expats nothing changed, being that income earned in years before they become taxable resident will not become taxable no matter when it’s brought to Thailand.
That’s all. Do *not* state that “expats remain untaxed” merely because because dta with your particular country happens to protect your particular income from being taxed in Thailand!
There is no such general rule!