Transcript of the above video: 

I wanted to make this video to do kind of a final, this is kind of my roundup analysis from now and I think this will hold for at least the relatively foreseeable future regarding the DTV, Thai Tax policy and what you need to look at when you're doing analysis as to what visa may or may not be best for you or whether or not the DTV may even be a good avenue for you at all. And it may be for some folks and may not be for other folks but the big thing to understand is underlying Thai Tax policy. 

Now I've gotten into it with a bunch of people on this platform and there are all kinds of people out in the real world have all kinds of issues with me and my opinions regarding tax policy, restricted occupations here in Thailand, what I refer to as tax stamp-pimps and all kinds of other nonsense related to tax. I'm going to leave that aside for the moment and suffice it to say one element, not the only element, but one element with regard to analysis on tax liability etc., here in Thailand, will fall to physical presence within the Kingdom, at least to one degree or another because that takes you into the realm of whether or not you will be assessed for certain types of liability and then whether or not certain funds or certain perhaps gains and things will be basically held against you in terms of paying for said liability in a tax context. The point I'm trying to make is physical presence in Thailand is going to I think for the foreseeable future, be at least one major component of assessing liability for tax purposes. The point I'm trying to make is the DTV factors into that, and let's get into the analysis. 

I thought of making this video after reading a recent article from the Pattaya Mail, that is pattayamail.com, the article is titled: DTV extension looks more of a hassle than a new border run. Quoting directly, and I urge those who are watching this video, go check out that article, the thrust of it goes in a different direction. That said, quoting directly: "The basic point is that a local Immigration extension will depend on continually updating documentation over the five years duration of the DTV. How will someone who started a cookery course in 2024 going to prove beyond reasonable doubt that he or she is still learning in say 2027? In the medium term, it will become apparent that DTV is a 5-year validity Tourist Visa requiring leaving Thailand at least twice a year - or once a year if your local Immigration can be persuaded to turn 180 days into 360.” And that's the reason for the quote in the title. It's that "180 days into 360" that got me thinking. You are going to have an immigration event with the Destination Thailand Visa, either in Thailand or by passing through a border coming back into Thailand, and this is where I think the nexus of the policy thinking behind future Thai Tax Policy is coming together behind the DTV.

Implicitly by going through either an extension here in Thailand or a border run to return to Thailand, you have been put on notice effectively that you have been in Thailand for 180 days and you are coming back in with that in your head. And I'm not saying that necessarily attaches tax liability to you; further facts need to be analyzed in your given situation, but that being said, that's why they are designing it this way. The more I have studied Immigration Law I ended up sort of drifting into Tax Law because weirdly enough, they actually intersect a lot and then, as you understand Tax Law, you start to see what drives policy thinking behind tax laws and in certain contexts, it also drives Immigration Law and that's where I think we are sitting with regard to the DTV. Again, the point I am trying to make is no matter what happens with the DTV, moving forward you will have to go through an Immigration event - what I would call an Immigration event - either an extension of status in country or a Border Run and return to Thailand but either of those two things are an affirmative event that can be documented. And I would argue it could also be construed - again depending on underlying circumstances - as a taxable event because from that point forward, there's no question you have spent more than the allotted 180 days because they will be able to track it and trace it through the Digital Immigration System and there won't be any question as to that element of possible tax liability analysis in the future. So that is something to keep in mind with regard to the DTV. And I can definitely see a situation where they require - in order to keep coming back into Thailand for those six-month intervals or to get your extension in the future, some sort of interaction with a Digital Terminal to basically pay taxes in order to keep going.

As I said to everybody that's on standard Retirement Visas and other types of standard visas here, don't worry about all this tax stuff until it becomes part of your visa extension process. Well, it looks to me like from the standpoint of the DTV, it's effectively part of the process from jump street by dint of the fact that that Immigration act of getting you more than the 6 months will effectively lock you in at least with regard to the tax residence - for lack of a better term - element of any analysis of further tax liability within that given calendar year. After you have passed that threshold with Immigration you'll be able to clearly be evidenced that okay I am under tax jurisdiction here in Thailand and they are going to be able to deal with you on an every 6 months basis to continue making sure you have kept up with respect to your tax liabilities with respect to how your earnings possibly offshore interact with Thailand etc. and maintaining tax compliance on an ongoing basis through the Destination Thailand Visa thereafter.