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What are the tax implications for UK directors on a DTV visa working remotely in Thailand?

Anonymous *************
asked Sep 9, 2026
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DTV Visa + UK Limited Company Tax. We are two directors running a UK Ltd business with only UK customers, no Thai customers. We get paid via the company bank by salary and dividends. Does anyone have certainty on the tax situation that applies to us in Thailand?
Answer summary
Two directors of a UK Ltd company, earning through salaries and dividends from the UK, are inquiring about the tax implications of living in Thailand under the Destination Thailand Visa (DTV). Key points discussed include the 180-day tax residency rule, which defines tax obligations based on days spent in Thailand; the impact of remitting foreign income; potential risks regarding a Permanent Establishment (PE) due to their roles; and the benefits of the UK-Thailand Double Taxation Agreement. There is debate over whether they will incur Thai taxes on their overseas income, particularly if they do not exceed the residency threshold.
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Mario ************
Mario ************
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.
********
):

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?
Greg ********
Greg ********
@Mario ***********
No business activities within Thailand - Tax Scope: Unlike local Thai companies that pay tax on worldwide income, a foreign company with a PE is taxed only on the net profits arising from its business activities within Thailand
Mario ************
Mario ************
@Greg *******
Careful with that logic. "No business activity in Thailand" means the business operates elsewhere. If you're a director living in Thailand and doing all the client work or closing deals from your laptop, you are the BUSINESS ACTIVITY. Under DTA rules and Section 76 bis, that creates a "place of management" / PE risk right on Thai soil. And even if the company dodges corporate tax, the second you bring that money in to live on, Personal Income Tax catches you anyway.
Greg ********
Greg ********
@Mario ***********
You are clueless. Tell me how many DTV holders have been caught by the TRD and made to pay tax on monies remitted to Thailand. Please cite the cases.
Greg ********
Greg ********
@Mario ***********
Mr Google at it again. Stop bedwetting at your age and stick to Switzerland.
Anonymous *************
Anonymous *************
OP
Thanks for your helpful answer Greg. So this is two remote workers with laptops, no permanent office, so co-working spaces and cafes with 100% non-Thai customers. Should we get a Thai tax advisor?
Greg ********
Greg ********
Anonymous participant If you want reassurance then ask an international advisor bit I doubt you will be liable for company tax in Thailand under PE. Remittance it might be possible in theory but in reality you will not be in the real world. These are the tax advisors we had available to us. Trust these more than a Swiss bloke with Google
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David ********
David ********
once you're in thaiiland 180 days a year you become a thai tax resident but if you're already paying income tax in uk you won't need to pay it in thailand as well. Depending on what you're doing You may be able to set up a holding company in Dubao and pay your income tax there if you're beoming a non uk tax resident.
Anonymous ******************
Anonymous ******************
From what I understand, if your personal money is taxed in the UK. You would be able to deduct it from the Thai income remitted tax.

Not sure you would still be a UK tax resident? From what I've heard being a double tax resident can be messy.

Plenty of accountants offer free advice online with the hope you use them for your accounts.

Might be easy to go as a none UK tax resident. And pay Thai tax on the income? The Thai tax allowances are fairly good for the amount of money needed to be remitted to live.

Not much of an answer sorry it's not straightforward. I used chatgpt and the free accountant meetings to learn about my situation.
Bob **********
Bob **********
Anonymous participant 999 hrs not going to pay any tax in Thailand
Greg ********
Greg ********
So you will still pay tax in the UK? If you were tax resident in Thailand your income remitted to Thailand would be assessable. There is a Double Taxation Treaty between UK and Thailand. Any tax paid in the UK would be deductible against the assessable income remitted. If the rate of tax is higher in Thailand than what you paid in the UK then you may be liable for the difference. That is the theory. In practice I very much doubt you will be paying any tax in Thailand unless remitting very large sums into Thailand.
Mario ************
Mario ************
@Greg *******
And don’t forget the situation that they are not normal remote workers. They are the directors of the company. That means the main management place of the company will relocate with the directors to Thailand if they stay longer than 179 days per year. So the UK company could be as well be taxed in Thailand under certain circumstances.
Greg ********
Greg ********
@Mario ***********
No business activities within Thailand not liable for tax - Tax Scope: Unlike local Thai companies that pay tax on worldwide income, a foreign company with a PE is taxed only on the net profits arising from its business activities within Thailand
Greg ********
Greg ********
@Mario ***********
There is more chance of Margo Robbie dating you than the TRD doing that. Stop bedwetting and get back to reality or is it Thai bar girls giving you tax advice? PS: are you a Thai Tax Resident and have you ever paid tax or dealt with tax issues in Thailand?
Mario ************
Mario ************
@Greg *******
If the company is just one or two persons doing all the billable work and signing deals while sitting in Thailand, the Revenue Department can argue the core business activity is happening in Thailand. That’s fact and clearly stated in the Thai tax law.

Even if the UK Ltd owes 0% Thai corporate tax, once you remit dividends or salary into Thailand as a tax resident (180+ days), it falls under Thai Personal Income Tax.

Foreign substance protects corporate profits, but personal remittance is where most expats actually get tagged.

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