What Do Thailand's Latest Regulatory Changes Mean for Expats?

Around the world, governments and regulators have been tinkering with the rules that affect how people live, work, and manage their finances across borders. The UK has legislated changes to its Inheritance Tax framework that will bring unused pensions within scope for the first time from April 2027. Australia has finalised changes to its superannuation tax regime for large balances. Domicile-based tax systems are being replaced with residence-based models, shifting the goalposts for expatriates who assumed that moving abroad meant moving away from a former country's tax net.

For expatriates, it can be tempting to believe that once you have settled in a new country, the regulatory landscape around you is relatively fixed. In practice, the opposite is often true, and this is particularly relevant for those living in Thailand, where several recent changes deserve your attention.

Property: Thailand's crackdown on nominee ownership

Thailand has long restricted foreign ownership of land. For many years, a common workaround involved establishing a Thai limited company with majority Thai shareholders to hold the property on a foreigner's behalf, a nominee structure. Over the past year, Thai authorities have moved decisively against this practice.

New requirements now apply when incorporating a Thai company, amending company details, transferring shares, or changing directors, with authorities placing greater emphasis on verifying genuine investment and the true source of funds behind Thai shareholdings. Government agencies are also sharing information more closely with one another, meaning a concern raised by one authority can prompt a look from another. Thousands of companies have already been flagged for further review, and further legislative changes have been proposed that would strengthen the consequences for those found to be using nominee arrangements.

For expatriates who own or are considering purchasing property in Thailand, the direction of travel is clear: structures that may previously have been treated as standard practice are now subject to much closer scrutiny. Understanding how your property is held, and whether your arrangements are compliant, is an area that may benefit from review.

Wise: new regulation, new restrictions

Wise has been transitioning Thailand-based customers to a locally incorporated entity, licensed and regulated by the Bank of Thailand, with the move being phased in during 2026.

The new licensing brings practical benefits for Thailand-based users, including the ability to fund a Wise account from a local Thai bank and integration with Thailand's PromptPay payment network. However, the change also introduces restrictions that affect how expatriates manage their cross-border finances. Transfers between two foreign currencies, without routing through Thai Baht, are no longer supported from a Thailand-based Wise account. Foreign currency amounts received from abroad may now be automatically converted to Baht. Sending non-Baht currencies directly overseas can require conversion to Baht first, meaning two sets of conversion fees.

These changes illustrate a broader point: the platforms and tools expatriates rely on to manage their money are themselves subject to evolving regulation. What worked seamlessly a year ago may now operate differently, and the terms under which your funds are held and moved can change with relatively little notice.

For clients considering Wise for cross-border transfers, we've set up a dedicated page with an exclusive fee-free transfer of up to £1,000 (or equivalent) for new accounts: wi.se/melbournecapital. If you'd like a hand setting it up, we're happy to walk you through the process.

Why does investment and retirement structure matter for expats in Thailand?

For expatriates drawing an income in Thailand, the structure in which investments and retirement assets are held can have a meaningful impact on how that income is received and treated locally. Whether assets are held in your personal name, within a trust, or under an insurance-based structure can affect how local tax and regulatory requirements apply, and this is an area that benefits from careful consideration as rules evolve.

An arrangement that may have been appropriate when you first moved to Thailand may no longer be the most suitable structure as the local regulatory environment changes. This applies not only to investments and pensions, but also to the way property is held and the platforms used to move money across borders.

What should expatriates consider?

Rather than reacting to each individual change as it arises, a more effective approach is to ensure that your overall financial plan is built to accommodate change. This may include reviewing the structure of your investments, pensions, and property holdings to ensure they remain appropriate for your current country of residence. It may also mean understanding how changes in one jurisdiction, such as the UK's pending Inheritance Tax changes, interact with the regulatory environment where you now live, and keeping your estate planning, beneficiary nominations, and protection arrangements aligned with your current circumstances.

Financial planning for expatriates is rarely static. The most resilient plans are those that are reviewed regularly and adapted as your personal circumstances and the regulatory framework evolve.

A considered approach to cross-border planning

At Melbourne Capital Group, we work with expatriates across Southeast Asia to help them understand the financial considerations associated with living and working internationally. Whether that involves reviewing how investment structures interact with local requirements, considering the implications of regulatory changes in Thailand or the UK, or coordinating retirement and estate planning across jurisdictions, our aim is to help clients make informed decisions based on their individual circumstances.

If you have not reviewed your financial arrangements recently, or if any of the changes mentioned above may be relevant to your situation, it may be worth having a conversation with a qualified adviser. I am Adil Rafiq, a Private Wealth Manager with Melbourne Capital Group. You can reach me at adilrafiq@melbournecapitalgroup.com or connect with me on Linkedin.

Frequently Asked Questions

Can foreigners still use nominee company structures to own property in Thailand?

Thai authorities have significantly increased scrutiny of nominee structures, where a Thai limited company with majority Thai shareholders holds property on a foreigner's behalf. New requirements now apply when incorporating a company, amending company details, transferring shares, or changing directors, with greater emphasis on verifying genuine investment and the true source of funds. Thousands of companies have already been flagged for review, and further legislative changes have been proposed that could strengthen the consequences for those found to be using these arrangements. Expats who own or are considering purchasing property in Thailand may want to review how their property is currently held.

What changed for expats using Wise in Thailand?

Wise has been moving Thailand-based customers to a locally incorporated entity, licensed and regulated by the Bank of Thailand, with this transition phased in during 2026. The change brings some practical benefits, including funding accounts from a local Thai bank and integration with the PromptPay payment network. It also introduces restrictions: transfers between two foreign currencies without routing through Thai Baht are no longer supported from a Thailand-based Wise account, incoming foreign currency may be automatically converted to Baht, and sending non-Baht currencies overseas can require conversion to Baht first, potentially resulting in two sets of conversion fees.

How will the UK's 2027 pension inheritance tax changes affect British expats?

From April 2027, unused UK pensions will fall within the scope of UK Inheritance Tax for the first time under legislated changes to the framework. This is a shift from the current treatment and may affect how British expatriates approach estate planning, beneficiary nominations, and the coordination of pension and inheritance tax planning across jurisdictions. How this interacts with the tax rules of an expat's current country of residence, such as Thailand, is worth reviewing on an individual basis.

Do I need to review my financial arrangements because of these regulatory changes?

An arrangement that was appropriate when you first moved to Thailand may no longer be the most suitable option as property rules, payment platform regulations, and pension tax treatment continue to evolve. Rather than reacting to each change individually, a more effective approach is reviewing your overall financial plan, including how investments, pensions, and property are structured, so it remains appropriate for your current circumstances and can adapt as regulations change further.

Does Melbourne Capital Group provide tax or legal advice on these changes?

Melbourne Capital Group does not provide tax, legal, or immigration advice directly. Matters such as Thai property structuring, source-of-funds requirements, and UK inheritance tax planning should be considered alongside appropriately qualified professional advisers. We can help clients understand how these changes may relate to their broader financial plan and coordinate with specialist partners where needed.

About the Author

Adil is a Private Wealth Manager with Melbourne Capital Group. He works with British expatriates and internationally mobile professionals, helping them understand the financial considerations associated with cross-border wealth management, retirement planning, protection solutions, estate planning and long-term financial planning. Adil is UK-qualified with extensive experience in financial services, including previous roles at J.P. Morgan and a UK Independent Financial Adviser as well as service in the military. Having lived and worked internationally, he understands many of the practical challenges faced by expatriates managing their financial affairs across different jurisdictions. He works with clients to develop financial strategies that align with their individual objectives and circumstances, while recognising that tax and legal matters should be considered with appropriately qualified professional advisers where required.

Disclaimer

This article is provided for general information and educational purposes only and does not constitute financial, investment, legal or tax advice, nor is it a recommendation to take any particular course of action. The information is based on legislation and guidance available at the time of publication, which may change without notice. Individual circumstances differ, and readers should seek independent professional advice, including legal and tax advice where appropriate, before making any financial decisions. Any financial services provided by Melbourne Capital Group are subject to the scope of the firm's applicable regulatory licences and the laws of the relevant jurisdictions.

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