Defensible exit planning for Australian high earners relocating to Thailand. No vague promises — just the numbers, the rules, and the evidence that holds up.
Every calculation below uses the same assumptions the ExitProof calculator applies when you select "Thailand" as your destination. These are not optimistic projections — they reflect current ATO rules (ITAA36 s6(1), TR 2023/1) and Thai Revenue Department law as of 2024.
* Thailand has lower income tax rates than Australia but does tax employment and foreign-sourced income remitted to Thailand. Investment income remitted to Thailand is taxed. One-time CGT exit event on accrued investment gains (~$40k at departure). Non-resident CGT on shares = 0% from departure.
* Exit CGT on $800k portfolio at 7% growth: ~$75k. Thai tax on Australian rental income remitted to Thailand — 15% withholding at source under DTA + Thai rates apply to residual. Keep AU property documents clean: tenancy agreement, property manager statements.
* CGT exit event on $2M portfolio: ~$140k. Thailand taxes worldwide income for residents. Business owners and founders operating through a Thai company structure need careful substance and transfer pricing planning. Corporate tax at 20% applies to Thai company profits. LTR visa holders may qualify for remittance-based taxation.
A person is a Thai tax resident if they spend 180 days or more in Thailand during a calendar year. Thai tax residents are taxed on worldwide income (including income remitted to Thailand). The Revenue Department applies this on a calendar year basis.
| Concept | Threshold | Relevance for Australian high earners |
|---|---|---|
| 180-day rule | 180+ days physically present in Thailand in a calendar year | Primary threshold for Thai tax residency |
| Remittance basis | Foreign income remitted to Thailand is taxable regardless of source country | Key distinction from Australia — income not remitted may escape Thai tax |
| Employment income | Taxed in Thailand based on progressive rates (0–35%) | Can be offset by DTA with Australia (see below) |
| Capital gains | Generally not separately taxed; included in ordinary income | Share/crypto disposals taxed as income if remitted |
Thailand's Long-Term Resident (LTR) visa, launched under Thailand 4.0 policy, offers 4–10 year visas for qualified applicants with notable tax treatment benefits.
Australia and Thailand signed a comprehensive Double Tax Agreement in 2019, which entered into force on 1 January 2021. This is significant: unlike the UAE, Thailand has a DTA with Australia. Key provisions relevant to Australian expats:
Reference: ATO Tax Treaties; Thai DTA text via Thai Revenue Department
Reference: Thai Revenue Department; Thailand BOI / LTR scheme details at Thailand Board of Investment
Under s6(1) ITAA36, you are an Australian tax resident if you satisfy any one of four tests. You must fail all four to be a genuine non-resident. The ordinary concepts test is the battleground.
| Test | What it asks | Thailand-mover risk |
|---|---|---|
| 1. Ordinary concepts | Does your presence in Australia feel "usual and settled" — or temporary and casual? | HIGH — keeping an AU apartment + regular school-holiday returns sustains "continuity of association" |
| 2. Domicile | Is your domicile in Australia? (Presumed yes unless you establish a permanent place of abode overseas AND intend to stay) | MEDIUM — Thai rental lease + intent documentation required to counter domicile presumption |
| 3. 183-day test | Have you been physically present in Australia for 183+ days in the income year? | LOW — if you actually live in Thailand, you'll fail this |
| 4. Superannuation test | Does your employer pay compulsory superannuation contributions in Australia? | MEDIUM — remote work for an AU employer may still generate super contributions |
The 2019 Australia-Thailand DTA (in force January 2021) changes the exit calculus compared to no-DTA destinations like the UAE. Here's a clear-eyed assessment.
Each item directly addresses one of the six ordinary concepts factors (TR 2023/1 para 20). The DTA provides a backstop, but only if ordinary concepts evidence establishes genuine Thai residency first.
Headline numbers. Run the full comparison →
| Thailand | Dubai | Stay in Sydney | |
|---|---|---|---|
| Personal income tax | 0–35% progressive (remittance basis) | 0% | 37%–47% |
| AU CGT for non-residents | 0% on shares (post-departure) | 0% on shares (post-departure) | N/A |
| DTA with Australia | Yes (2019 DTA, in force 2021) | None | N/A |
| Evidence burden | Medium (DTA provides backstop) | High (no treaty fallback) | N/A |
| Residency visa options | LTR (4–10yr), Elite (5–20yr), non-immigrant B | Golden Visa (10yr) | N/A |
| 5yr leave-vs-stay delta (~$400k earner) | ~+$700k* | ~+$748k | Baseline |
| 10yr leave-vs-stay delta (~$400k earner) | ~+$1.62M* | ~+$1.69M | Baseline |
* Thailand figures account for Thai income tax on remitted foreign income and employment income. Net delta depends on remittance strategy and employment structure. Dubai remains higher on pure tax savings but comes with higher evidence burden.