Living in Thailand: tax residency, withholding tax, and inheritance tax

Thailand treats you as a tax resident after a stay of 180 days per year. France may, however, continue to consider you as domiciled there: only one of its three criteria is sufficient. In this case, the convention of December 27, 1974, governs the relationship between the two countries. Thailand also has its own inheritance tax, which is not covered by the convention.

This page is based on information from the Thai Revenue Department, the English translation of its Revenue Code, and the relevant tax treaty. It does not provide the income tax rates: the official Thai government website displays them for 2013 and 2014 and does not indicate that the rates have been extended. It also does not cover Thai social security, investing savings in Thailand, or visas.

The 180-day threshold: read the source before counting

The Revenue Code, in its English translation published by the administration, sets out the rule in Section 41. A person who resides in Thailand for 180 days during the tax year is deemed a resident of Thailand. The administration's "Individuals" page adds that non-residents are only taxed on their Thai-source income.

The government's official documents don't all define the threshold in the same way. The translation of the Revenue Code and the infographic for foreigners state "180 days or more." The "Individuals" page and the introduction to the agreements state "more than 180 days." We're not taking a definitive stance. If your number of days is approaching 180, don't rely on the one-day margin of error and have the Thai text checked, as it's the only legally binding document.

For foreign-source income earned since January 1, 2024, the infographic links taxation to two conditions: a stay of at least 180 days and the remittance of funds in Thailand. This rule, its exceptions, and the foreign tax credit are the subject of our dedicated page.

What Thailand says, and what this page doesn't quantify

Income from Thai sources is taxable, whether paid in Thailand or abroad. The annual tax return is filed using form PND90 or PND91. The "Individuals" page sets the filing and payment deadline at the end of March of the following year, and provides for a semi-annual filing deadline, before the end of September, for certain income categories. This page is dated March 2024; any extensions should be verified with the tax authorities.

Married couples can file a joint tax return or separate returns, according to another page on the administration's website. It provides for a child deduction of 15,000 baht for each spouse, or 17,000 baht if the child is attending school at the required level.

We do not use any rates from the current schedule. The rates displayed are for 2013 and 2014, with no indication of renewal: a rate from this page, applied to your situation, would be invalid. The current schedule can be obtained from the administration or a local council.

Dividends and interest: withholding tax

Section 50 of the Revenue Code provides for a withholding tax of 10 % on specified dividends. For certain income, including interest and certain capital gains on the sale of debt securities, the rate is 15 %. The withholding tax does not apply to interest paid by a payer that is not a legal entity to a resident taxpayer. The exact paragraphs can be found in the Thai text.

The Franco-Thai tax treaty caps dividends only in one case: when a beneficiary company directly holds at least 25 % of the paying company's capital (15 % or 20 %). Details can be found on our page about the treaty. The treaty does not specify a cap for individuals. France, for its part, grants a tax credit on dividends from Thai sources, capped at 25 % of their gross amount.

A page from the Revenue Department lays out a principle: when the Revenue Code and a tax treaty establish different rates, the rate most favorable to the taxpayer applies. The page dates from 2014; this principle should be considered before any decision is made.

Inheritance tax in Thailand: a separate tax, outside the agreement

The 1974 convention only covers income taxes. The French administrative register does not include information on wealth, inheritances, or gifts in Thailand. Therefore, an inheritance involving Thailand falls under both Thai and French law, each within its respective jurisdiction.

Thai law includes an Inheritance Tax Act (BE 2558). According to the translation published by the Revenue Department:

This translation has no official value. The current threshold and property valuation are found in the Thai text and its regulations.

On the French side: what remains taxable

Moving to Thailand does not automatically terminate French tax residency. The doctrine establishes three criteria: the primary residence or place of residence, professional activity, and the center of economic interests. It states: "It is sufficient that one of these criteria is met." Our page on Article 4 B provides further details.

If both states consider you a resident, Article 4 § 2 of the convention establishes the following criteria in this order: permanent home, center of vital interests, habitual residence, nationality, and agreement of the competent authorities. Nationality is included.

If France ceases to be your tax residence, you will only be taxed there on your French-source income, subject to tax treaties. The minimum tax rates for non-residents range from €20 to €29,579 for income received in 2025, with the option to use the average rate when it is more favorable. The French wealth tax (IFI) continues to apply to your real estate assets located in France, if your net taxable assets exceed €1,300,000 as of January 1st.

Leaving Thailand: the tax authorization to leave

A foreigner leaving Thailand must apply for a Tax Clearance Certificate (form P.1) in three cases: if they owe taxes or have arrears, if they need to declare and pay taxes for a foreign company operating in Thailand, or if they have taxable income as a public performer. The application must be submitted within 15 days of departure. Simple transit and stays of up to 90 days per year without taxable income are exempt. Departing without a certificate, when required, is subject to a 20% surcharge on taxes and a fine of up to 1,000 baht.

Thai inheritance: numerical example (fictitious profile)

Situation. A French woman residing in France, a fictitious profile, receives an inheritance from her father located in Thailand, valued at 130,000,000 baht (assumptions).

Issue. She wants to know if this inheritance is taxed in Thailand and by what deadline.

Strategy. It applies the threshold of 100 million baht and the two rates of the law, then notes the period of 150 days from receipt, set at March 1, 2027.

Result. The portion exceeding the threshold is 30,000,000 baht. For 5 descendants (%), the tax is 1,500,000 baht; for 10 other beneficiaries (%), it would be 3,000,000 baht. An inheritance of 90,000,000 baht would not exceed the threshold. The deadline of March 1, 2027 + 150 days falls on July 29, 2027.

This profile is fictitious. The calculation does not convert to euros and says nothing about the valuation of the assets, the applicable threshold, or the French treatment of this inheritance.

Living in Thailand: what changes depending on your situation

• Your number of days of attendance during the calendar year.
• The date of earnings and the date of remittance of your foreign source income.
• The nature of your income: dividends, interest, rent, pensions, salaries.
• Whether or not you maintain your home, your business or your economic interests in France.
• The location of your assets and your relationship to your heirs.

No results are guaranteed. These points are examined case by case, with a Thai legal professional for local law.