Thailand: The 180-day rule and the taxation of foreign income repealed

For a foreigner staying in Thailand for 180 days or more in a calendar year, foreign-source income earned from January 1, 2024, onwards is taxable in Thailand as soon as it is remitted there, in whole or in part, even in a later year. This is described in the infographic from the Thai Revenue Department, the only Thai source consulted for this page (PDF titled "How do foreigners living in Thailand pay tax?", undated).

This page presents this rule and what the source says about it. It does not provide rates, a scale, or a filing deadline: the infographic does not contain these. It also does not address visas. For Thai law, local advice is still necessary.

The two-condition rule

Infographics poses two conditions, which are cumulative.

The threshold is written "180 days or more": 180 days meet the condition, 179 do not. The source indicates that the fiscal year is the calendar year.

Thai-source income is taxable whether paid in Thailand or abroad: the infographic states "whether such income is paid within or outside Thailand." The 180-day remittance requirement applies to foreign-source income earned from January 1, 2024.

When income is earned one year and remitted another, the table on page 3 of the infographic links the number of days of stay to the year in which the income is earned. This table should be checked against the original PDF before any significant remittance.

What the declaration contains

The Thai tax return is filed using form PND90 or PND91, according to the infographic. It includes:

• Thai-source income earned during the year; ;
• foreign source income "remitted to Thailand during the tax year".

According to this description, the tax base includes amounts remitted during the year, not all income earned abroad. In the case of partial remittance, the infographic indicates (page 5) that the taxable amount is allocated accordingly; this page does not detail this allocation.

The two exceptions

The source lists two situations where remitted foreign income is not taxable.

1. Income earned before January 1, 2024. It targets foreign-source income "derived before 1 January 2024 and remitted into Thailand in a later tax year." The table on page 3 distinguishes between income earned before 1 January 2024 and income earned from 1 January 2024 onwards.
2. Foreign national who is not a Thai tax resident. Foreign-source income derived by a foreigner who is not a Thai tax resident is not taxable, even if subsequently remitted. The infographic uses no other definition of residency than the 180-day threshold.

Tax already paid abroad

The infographic indicates that income tax paid abroad can be credited against Thai taxes: "Income tax paid abroad can be credited against Thai taxes." It refers to the applicable double taxation treaty. It does not specify how the credit is calculated. This page does not describe the maximum amount or the required supporting documentation.

What the source does not provide

This information can be found in the documents and pages of the Thai tax administration, or consulted with local advisors. This page does not draw any conclusions from it.

On the French side: attention is focused on tax residence

The Thai threshold does not resolve the issue of French tax residence, which is governed by its own criteria. Article 4 B of the French General Tax Code (CGI) establishes three criteria, as explained in the Official Bulletin of Public Finances (BOFiP) (BOI-IR-CHAMP-10): the home or principal residence, the professional activity, and the center of economic interests. According to the BOFiP, "it is sufficient for one of the criteria to be met.".

A person can be considered a resident of both France and Thailand. The "Resident of France" page on impots.gouv.fr (updated on 27/01/2026) specifies that, in this case, the applicable tax treaty determines eligibility and that the treaty's definition of resident status "will always prevail" over that of tax domicile. It describes a general set of criteria (permanent home, center of vital interests, habitual residence, nationality), without applying it to any specific country.

A tax treaty between France and Thailand exists: signed on December 27, 1974, and supplemented by an exchange of letters dated August 20, 1999, and March 6, 2000, it concerns income tax (BOI-ANNX-000306, version of April 29, 2026, treaties in force as of January 1, 2026). This page does not describe its content: its residency criteria, as well as its treatment of dividends, interest, and capital gains, should be verified in the treaty text.

Tax residency in Thailand: a numerical example (fictitious profile)

Situation. A consultant, a fictional profile, spends 190 days in Thailand in 2025. He receives 1,100,000 THB in Thai-source income. He also earns 2,400,000 THB in foreign-source income and remits 700,000 THB of that to Thailand in the same year (amounts and days: assumptions).

Issue. What proportion of his income is included in the Thai tax return?

Strategy. Apply the two conditions outlined in the infographic: 180 days or more, and remittance in Thailand. Count Thai income and only foreign income remitted during the year.

Result. With 190 days, the 180-day condition is met. The tax base is 1,100,000 + 700,000 = 1,800,000 THB. The 1,700,000 THB of unremitted foreign income is not included in this base. With 175 days, the first condition would not be met: the tax base would fall to 1,100,000 THB, a shortfall of 700,000 THB. With exactly 180 days, it would be met.

This profile is fictitious. The calculation adds up amounts; it does not apply any rates, because the source does not provide them, and it does not take into account any possible deductions.

Tax residency in Thailand: what changes depending on your situation

• Your number of days of attendance on the calendar year.
• The date you earned your income : before or after January 1, 2024.
• The amount and schedule of your discounts to Thailand.
• Your tax resident status in Thailand and in France, which is judged case by case.
• Tax already paid abroad and the applicable convention.

No results are promised: the rule depends on your situation.