Thailand: crypto taxes when leaving Germany

• System (Section 41, Thai Revenue Code): Foreign income is only taxable if the person was tax resident in Thailand in the year it was earned (from 180 days in a calendar year, counted cumulatively) and it is transferred (remitted) to Thailand. Until the end of 2023, the transfer had to take place in the same calendar year; since 1 January 2024 (Por. 161/2566, 162/2566), this restriction no longer applies. Income from 2024 onward is taxable on any later transfer, income from before 2024 permanently stays tax-free.
• Disposals: Tax-free until the end of 2029 when sold through a domestic exchange, licensed broker, or licensed dealer regulated by the SEC (Ministerial Regulation No. 399, retroactive to 1 January 2025); individuals only. Not exempt: foreign or unlicensed platforms, P2P transactions, DeFi swaps, decentralized exchanges, derivatives.
• Filing: The rule exempts from tax, not from the declaration obligation. The gains have to be declared in the Thai tax return (Form PND.90 or PND.91; deadline 31 March, or 8 April for electronic filing).
• Staking, lending, airdrops: Ordinary income, taxed once it reaches Thailand; staking, liquidity mining, and airdrops at market value on receipt. The receipt itself is taxable; a later increase in value can be exempt on sale through a licensed operator if the acquisition cost is cleanly documented.
• Mining and hard forks: Mining at market value on the day of receipt; electricity costs, hardware depreciation, and pool fees are deductible. Hard fork: no express rule; market value on receipt should be decisive, provided a tradable price exists at all.
• Method: FIFO or moving average cost, no LIFO; records kept for five years.
• VAT: 7 % VAT on transfers outside licensed platforms; transfers through licensed operators permanently exempt since 2024.

Year of departure

• Unlimited German tax liability only ends once residence and habitual abode are actually given up. Tax residency in Thailand arises with 180 days or more in a calendar year, retroactively for the entire calendar year.
• A sale before Thai tax residency lies outside Section 41 and stays permanently tax-free in Thailand, even if the money is remitted years later. What matters is the calendar year, not the date of the move: anyone moving in July, selling in March, and reaching 180 days by year-end counts as resident retroactively; the March sale is captured.
• Documentation: account statements, exchange transaction histories, and, in case of doubt, a record of days spent in the country. Thailand participates in the CRS, and account statements are increasingly cross-checked against immigration data; an informal grace period in enforcement shouldn't be mistaken for a permanent loophole.

First year after leaving

• Once Thai tax residency is established: a sale through an SEC-licensed Thai exchange is tax-free until the end of 2029; through a foreign exchange, P2P, or a decentralized platform, the gain is subject to progressive income tax of up to 35 % on a later transfer, regardless of the time in between. Gains never remitted to Thailand trigger no Thai tax.
• LTR visa: “Wealthy Pensioner” (at least $80,000 of passive income a year) and “Wealthy Global Citizen” are exempt from taxation of foreign income (Royal Decree No. 743), for up to ten years; “Highly Skilled Professional” pays a flat 17 % rate on Thai income.

More than ten years

• Nothing changes for income tax purposes (current position). No general wealth tax; inheritance: an allowance of THB 100 million (several million euros converted) per heir, above which a comparatively moderate rate applies.
• With no German-Thai inheritance tax treaty, German extended unlimited inheritance tax liability applies for German nationals if the deceased or donor was fully taxable in Germany within the last five years before the inheritance; after more than ten years, this window is closed.

Moving on to a third country

• No exit taxation for privately held crypto assets; foreign gains not yet remitted trigger no subsequent Thai tax, since only the actual transfer matters. If an LTR visa was used, it should be checked before moving on whether any associated conditions (minimum-stay or proof obligations, for example) are affected.

Returning to Germany

• No special Thai tax as long as foreign gains not yet remitted stay abroad. Unlimited tax liability in Germany applies again upon re-establishing residence or habitual abode; the original acquisition date still counts. If a position has been held for longer than a year in total, a later sale in Germany is tax-free under § 23 EStG, regardless of whether, and for how long, it was tax-irrelevant in Thailand in the meantime.