Global Daily Tax News, Netherlands To Tax Pension Income Of Retirees In Thailand, (Dec 3, 2025)

A new double tax treaty was recently concluded between the Netherlands and Thailand that, among other things, enables the taxation of pension income at source.

The new agreement, which is expected to enter into effect no earlier than January 1, 2027, notably includes provisions that will enable the Netherlands to tax the pension income of Dutch citizens in Thailand under Dutch rules. The rules will apply both to pensioners residing in Thailand now and in the future.

The treaty will also expand mechanisms for the exchange of information in tax matters, and new provisions will be added to counter tax base erosion and profit shifting (BEPS).

The agreement will enter into force when both nations have completed their domestic ratification procedures. In the Netherlands, the treaty will be submitted to the Council of State for advice, before being submitted to the House of Representatives for approval.