The Destination Thailand Visa (DTV) grants legal permission to live and work remotely in Thailand, but it carries no tax exemptions.
Your tax liability in Thailand depends strictly on physical day counts and income remittance rules:
1. The 180-Day Tax Residency Rule:
* Under 180 days per calendar year: You remain a tax non-resident in Thailand. You will owe zero Thai tax on foreign-sourced earnings (salary or dividends from the UK Ltd), regardless of whether you bring money into the country.
* 180 days or more per calendar year: You become a Thai tax resident for that tax year (January 1 – December 31).
2. Thai Taxation on Foreign Remittances (Revenue Order Por.
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):
As a Thai tax resident, Thailand operates on a remittance-based system for foreign-sourced income:
* Offshore funds: Income kept outside Thailand in a foreign or UK bank account is not taxable in Thailand.
* Remitted funds: Any assessable income (salary or dividends earned after January 1, 2024) transferred into Thailand (via bank wire, ATM withdrawal, or local spending) is subject to Thai Personal Income Tax (progressive brackets from 0% to 35%).
3. Corporate Tax Risk: Permanent Establishment (PE)
Because you are both directors managing and directing the UK business while physically living in Thailand, Thai Revenue could argue that the company’s "place of effective management" has shifted, creating a Permanent Establishment (PE). If deemed a PE, the UK Ltd's profits could become subject to Thai Corporate Income Tax (20%).
4. UK-Thailand Double Taxation Agreement (DTA)
* The UK-Thailand DTA prevents the same income from being taxed twice, allowing tax credits to be claimed in the country of residence for taxes paid abroad.
* UK tax residency depends on the HMRC Statutory Residence Test (SRT). If you lose UK tax residency, director salary for duties performed abroad and dividends are treated differently under UK non-resident rules.
To give you more tailored advice, what is your planned duration in Thailand per calendar year, and will you remain UK tax residents under HMRC's Statutory Residence Test?