At Expat Tax Thailand, we have already received questions from concerned Dutch expats and people planning a move to Thailand who want to understand what the treaty may mean for their income, tax position and future plans.
At Expat Tax Thailand, we have already received questions from concerned Dutch expats and pre-move retirees who want to understand what the treaty may mean for their pensions, AOW, Thai tax position and future plans.
Many are asking where their Dutch pension will be taxed. Some are worried they could be taxed twice. Others want to know whether they should move before the new treaty takes effect.
The treaty has been signed, but it is not yet in force. That distinction matters.
This article answers seven of the most common questions Dutch nationals and expats are asking about the new Netherlands–Thailand tax treaty.
Netherlands–Thailand Tax Treaty Status
Signed: Yes
Date signed: 21 November 2025
Official treaty text: Published in Tractatenblad 2025, 94
Current position: Signed, awaiting ratification
Earliest practical effect: Potentially 1 January 2027, if the required steps are completed in time
Last updated: 23 June 2026
We will update this page as the treaty approval process develops. The treaty may affect how Dutch pensions, annuities, AOW and some other income are taxed once it becomes effective. Until then, the existing treaty position remains relevant.
1. When does the new Netherlands–Thailand tax treaty start?
The new treaty has not started yet.
It has been signed by the Netherlands and Thailand, but a signed treaty does not automatically become effective. Both countries must first complete their own approval steps. After that, they formally notify each other that those steps have been completed.
Once the second notification has been received, the treaty enters into force at the end of the following month.
For tax purposes, the key date is then 1 January of the next calendar year. In practical terms, if the treaty enters into force during 2026, it could start applying from 1 January 2027. If that process is not completed until 2027, the practical start date could move to 1 January 2028.
For Dutch expats, the safest message is this:
The treaty has been signed, but it is not yet active. However, 2026 is the right time to understand what may change.
2. Where will my Dutch pension be taxed under the new treaty?
This is the question many Dutch retirees in Thailand are now asking.
Under the signed treaty text, pensions, annuities and social security payments are covered by Article 18. In simple terms, the treaty gives Thailand taxing rights as the country of residence, but it also allows the Netherlands to tax pensions and social security payments that arise in the Netherlands.
That is why the treaty could have a real practical impact for Dutch pensioners receiving income from the Netherlands.
Under the old treaty, many Dutch retirees planned on the basis that private pension income could often be received without Dutch withholding tax, depending on their situation. In practice, some also paid little or no Thai tax because of Thailand’s remittance rules, allowances and deductions.
The new treaty may change that expectation.
The practical impact will depend on:
- The type of pension you receive
- Whether you receive AOW
- Whether you receive ABP or another government-linked pension
- Your total income level
- Whether you are Thai tax resident
- How much income you remit to Thailand
- Whether Thailand gives credit for Dutch tax paid
ABP and other government-linked pensions may need particular care, so recipients should not assume that their tax position will stay the same. For many Dutch retirees, the practical question is not just how much pension income they receive. It is how each part of that income is treated once the new treaty applies.
That is why the real impact needs to be calculated rather than assumed.
3. Will AOW, ABP and private pensions be taxed differently?
Possibly, yes. They should be reviewed separately.
Many Dutch expats in Thailand receive more than one type of Dutch income. For example, someone may receive AOW, a private pension, an ABP pension, an annuity or investment income.
The new treaty does not mean all of these are treated in exactly the same way.
AOW matters because it is a social security payment.
Private pensions matter because many Dutch retirees in Thailand have previously expected this income to be paid without Dutch withholding tax, depending on their situation. The new treaty may change that position.
ABP and other government-linked pensions may need particular care. Under the new treaty, pension income is dealt with under the pension article, even where the pension relates to former government service. For that reason, former civil servants and ABP pension recipients should not assume that their tax position will stay the same.
The key point is that you should not look only at your total income. You need to look at each income source separately:
- Where does the income come from?
- How is it treated under the treaty?
- Is it taxed in the Netherlands?
- Is it remitted to Thailand?
- Can Thailand give credit for Dutch tax paid?
For many Dutch retirees, the practical question is not just how much income they receive. It is how each part of that income is treated once the new treaty applies.
4. Will Dutch expats in Thailand be taxed twice?
The treaty is designed to reduce double taxation, not create it.
However, that does not mean there will be no tax cost. It may also mean a Thai filing obligation, depending on your circumstances.
Article 22 deals with double tax relief. In simple terms, if the same income is taxed in both countries, Thailand should generally allow credit for Dutch tax paid on that income, subject to treaty limits and the Thai filing position.
For some Dutch retirees, Dutch tax paid may reduce or even eliminate the Thai tax due on the same income. The outcome will depend on the income level, what is remitted to Thailand and how the Thai tax return is prepared.
The practical issue is often not full double taxation. It is proving the Dutch tax paid clearly enough for the Thai tax return.
Thailand may need to understand:
- What income was taxed in the Netherlands
- How much Dutch tax was paid
- Which tax year the income relates to
- Whether the income was remitted to Thailand
- Whether the income is assessable under Thai tax rules
- Whether a foreign tax credit can be claimed in the Thai return
For many Dutch expats, the key point is this: the treaty may provide the mechanism to prevent double taxation, but records and timing will still matter.
5. Will I need to file a Thai tax return in Thailand?
Possibly, yes.
The new treaty does not remove Thai domestic tax rules. If you are tax resident in Thailand and you remit assessable income to Thailand, Thai filing may still need to be considered.
The treaty helps decide which country has taxing rights and how double taxation should be relieved. It does not automatically mean that a Dutch expat in Thailand can ignore Thai tax filing.
For example, Dutch pension income may be taxed in the Netherlands and then remitted to Thailand. Thailand may still need to consider that income under its own tax rules. If Thai tax applies, the treaty credit mechanism may then become relevant.
This is where the practical work begins.
The treaty may explain the tax position, but the Thai tax return still needs evidence. The Revenue Department may need to see documents showing:
- What income was received
- Where the income came from
- Whether it was taxed in the Netherlands
- Whether it was remitted to Thailand
- When it was remitted
- Whether a foreign tax credit can be claimed
The key issue may be proving the position, not just calculating the tax.
6. What documents will Thailand need to prove Dutch tax paid?
This may become one of the most important practical questions for Dutch expats in Thailand.
If you need to claim credit in Thailand for Dutch tax paid, you will need clear supporting evidence.
The exact documents may depend on your circumstances and how your local Thai Revenue Department office handles the filing.
As a starting point, you should keep records showing:
- What income you received
- Where that income came from
- Whether Dutch tax was paid
- How much Dutch tax was paid
- Whether the income was remitted to Thailand
- When it was remitted
Useful documents may include:
- Annual pension statements
- AOW annual statements
- Jaaropgaven from pension providers
- Dutch tax assessments
- Provisional assessments, if final assessments are not yet available
- Proof of Dutch tax paid
- Thai bank statements showing remittances
- Foreign bank statements showing the source of funds
- Notes separating old savings from later income
This is not just an administrative point.
Thailand’s personal income tax filing period does not always align neatly with Dutch tax paperwork. A Thai return may need to be filed before final Dutch tax evidence is available.
That timing issue could become important if you need to claim credit in Thailand for Dutch tax paid.
For Dutch expats, 2026 is a sensible year to start organising records rather than waiting until the treaty is already effective
7. Should I move to Thailand before the new treaty takes effect?
There is no single answer.
The treaty may affect people in different ways depending on their income, assets, business interests and long-term plans.
For many people, tax will not be the only factor in deciding whether to move to Thailand. Lifestyle, healthcare, family, visa options, cost of living and personal goals are likely to matter more than tax alone.
However, the treaty may change the financial calculation.
A retiree receiving Dutch pension income may have one set of issues. A BV owner, e-commerce business owner or digital nomad may have a different set of concerns. Someone with significant savings, investments or planned remittances may need to look carefully at how and when money is brought into Thailand.
If you are planning to move from the Netherlands to Thailand, you should not rely only on old assumptions about how Dutch income, business profits, investment income or remittances will be treated.
Before making a final decision, it is sensible to review:
- Your expected income after moving to Thailand
- Your likely Dutch tax position after the treaty applies
- Your Thai tax residence position
- How much income or capital you expect to remit to Thailand
- Whether you have a BV, e-commerce business or other business interests
- Whether you have investment income, capital gains or exit-tax issues
- Your visa, healthcare and living costs
- Whether a different timing or visa route may improve your overall position
The question is not simply whether you should move before 2027. The more useful question is whether the new treaty changes the timing, structure or affordability of your move.
Do You Need Advice Now or Can You Wait?
Not everyone needs advice immediately.
If your position is simple, you may be able to wait. If the treaty could affect your income, move, business or remittances, it is worth reviewing your position before it becomes effective. You should consider taking advice if:
- You already live in Thailand and receive Dutch pension income
- You are planning to move to Thailand in 2026 or 2027
- You rely on receiving Dutch pension income gross
- You have higher pension income
- You receive AOW, ABP and private pension income together
- You have a BV or business in the Netherlands
- You have significant investments or remittances
- You are unsure what records Thailand will need
- You want to understand your likely tax position before moving
The treaty has not started yet, but that does not mean it should be ignored.
The right step now is to understand how you may be affected, so you can make informed decisions before the treaty becomes effective.
Concerned About the New Treaty?
If you are concerned about how the new Netherlands–Thailand tax treaty could affect you, book a free support call with our team. We will help you understand your next step.
