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No "Clarification On Nitty-Gritty Issues" Regarding Thai Tax?

Transcript of the above video: 

As the title of this video suggests, it is no one's favourite topic and that is tax. We are talking about it in the context foreign nationals here in Thailand. 

I thought of making this video after reading a recent article from the Pattaya Mail, that is pattayamail.com, the article is titled: Foreigners and their overseas income: what next? Quoting directly: “There is a view among some Thai lawyers that we must wait until July for clarification on nitty-gritty issues such as double taxation treaties and tax status of pensions. By that time, some expats will have passed 180 days of minimum residence necessary for tax liability in this category. However, other specialists argue that the Revenue” (I think they mean the Revenue Department; I don't know why they keep calling it the Revenue, but whatever) “needs not to clarify anything. After all, formal tax law did not change on January 1 2024." Yeah that's a good point. I have made that point many, many times. Quoting further: "There was simply the closing of a tax loophole which had enabled Thais or foreigners to delay transferring income here until a subsequent year." First of all I hate the term "loophole", there's just the law and there are just the regulations and there are just the practical implications stemming therefrom. When people use, and I'm not trying to point out Pattaya Mail or the article or anything, but when lay people use this terminology it reinforces certain notions like it's somehow wrong that folks were using the system as it was set up prior to January 1 to move money the way that they did. There was nothing wrong with that; there was nothing illegal about that. To call it a loophole I think diminishes the law, the fact that it's just the law. 

So the point I am trying to make with this video though is "no clarification on nitty-gritty issues". Well look there is clarification. You can find clarification. Contact a legal professional; contact someone who is dealing with Thai Tax Matters on a regular basis. Talk to them, give them your specific facts in your specific case and gain some insight and guidance thereby. We can advise. When I say "we", we have got Thai Tax lawyers in here and I am an American Tax Attorney. Again it occurs on an individual basis. It's this notion that clarification can only come from broad statements which are broadcast out there via either the print media or YouTube, it's just ridiculous. That's not how Law works, especially nuanced law like Tax Law where the specific facts in your case are going to drive the analysis of whether or not you owe certain amounts of taxes. So again while there is no sort of broad-based clarification, there never will be. At the end of the day there never will be broad-based clarification because everybody's case is different.

Now yes, yes, I understand, if they changed the law you could just read the law and say well that now applies to everybody. Again it does, but the specific facts when you do the analysis and interpret that law, the specific facts in the given case are going to change the outcome in terms of the legal conclusion drawn based on that law when applying those facts or vice versa, if you want to look at it that way, when applying the new law to those specific facts. 

But long story short, those waiting around for some sort of clarification coming broadly, some one size fits all answer with regard to tax policy and tax law and tax regulation here in Thailand, or in any other jurisdiction for that matter, you are going to be waiting a long time because that's not going to happen.