The risk of being caught by the police is through random stop and search, vehicle checkpoints or when police stop by the hotel you are staying at and ask to see the photocopy of your passport you provided for reception. Thereafter detention and deportation, likely not using the ticket you had already booked. Plus all the ban stamps. You will be escorted to the plane in the clothes they caught you in, such as swimwear. Your luggage has gone.

@Neil *****

Tax withholding is not the same as PE. One is about personal income tax and the other is about corporation tax. So you have gone from loads of examples to one. OK. LTR might be gone in five years, maybe next. For a junior person with a masters on $40k, just about making the cutoff, they will have think carefully about career development as there will none. Matters less for those already on a downward trajectory. The other option for those in global companies is to check whether they have a Thai subsidiary. Then there are other routes available. Post covid companies do recognise that employees might want to relocate to other countries. But employees might find their employer will pay them at local rates. Moving to somewhere like Singspore, no big change in salary. Thailand though will have a big cut. Outside of LTR Thai rates are bit regressive compared to UK and tax take only starts to improve once you get past £60-70k. LTR also apparently doesn't help if you want permanent residency.

@Neil *****

As a lawyer how would you interpret the meaning of "habitually" in the context of the section on PE in the UK-Thailand tax treaty (though I think similar wording in other tax treaties(, where it refers to an employees role in revenue generation or sales. Basically if you are involved in a sales transaction that involves a Thai client entity, then there is PE, unless that is not an habitual role. That includes contract signing on behalf of the company. Anyone in senior management could be asked to do that. Anyone hoping for career progression could do that. Basically the LTR restricts what you can do for your employer. I don't even know what means for employment rights in terms of redundancy. And the only person wanting to be in Thailand is the employee. There is no incentive on the employer to make this work unless they wanted to retain the employee, and that means senior management only. Everyone else is expendable. I've had conversations withe a senior tax law expert in a Hong Kong based merchant bank who knows a thing or two about international tax law and had a completely different view of this. What's more, Thailand can change their mind in 5 years time and those people who thought they were there for 10 years aren't. Name these global firms who are on board with shipping out senior managers to Thailand under this scheme. Virtually all senior managers in a public company are directly involved in revenue generation. Thailand require furnishing of accounts show no sales in Thailand otherwise they can levy a 5% charge.

@Kool ******

Think the 17% flat rate is on income derived in Thailand. Not income derived from outside of Thailand.

@Neil *****

But what is the incentive to the employer for the employee to be in thailand? The lawyers will come back and say risk cannot be eliminated, because you cannot guarantee there won't be business with thailand. The OP needs to read the Thailand-Canada tax treaty carefully because that will have a section on PE.

@Alex ******

Yes, BOI told me the scheme is designed to create advantage for the employee not the employer. Permanent establishment is the risk that the employer is liable to thai corporation tax based on your activities in thailand. Also while ltr means thailand won't charge income tax on your salary from Canada, Canada might.