The test is in section 41 of the Revenue Code and is purely a day count. The days need not be consecutive, and holding a long-stay visa or owning property makes no difference either way.

Non-residents pay Thai tax only on income that arises in Thailand, which includes rent from Thai property. Residents pay progressive personal income tax of up to 35% and, since 1 January 2024, are also taxed on foreign income earned from that date when they remit it to Thailand, in whatever year the transfer happens. Income earned before 2024 is outside the rule. Holders of a Long-Term Resident visa in three of its four categories are exempt on overseas income.

This matters when funding a purchase. A resident who brings in current foreign earnings to pay for a property may create a Thai tax liability. A non-resident, or someone remitting pre-2024 savings, should not. Changes to the remittance rule have been proposed more than once, so check the current position and take advice in both countries. See rental income and tax and sending money to Thailand.