Poland-Thailand Double Taxation: Property Guide 2026

A Polish national buying a condominium in Bangkok for 5 million THB will face at least four separate tax obligations in Thailand alone. Then, upon returning home, that same investor discovers the rental income must be declared again in Poland. There is no double taxation treaty (DTT) between Poland and Thailand. That sentence is worth reading twice.

The absence of a bilateral tax agreement means a Polish tax resident cannot automatically offset Thai taxes against Polish liability under treaty provisions. The only available relief is a domestic Polish mechanism - the so-called 'abatement relief' - which, following a 2021 legislative amendment, is capped at just 1,360 PLN per year. In practical terms, an investor pays tax twice: once in Thailand and once in Poland, with negligible relief.

Cambodia presents a structurally similar situation - no DTT with Poland either - but the effective tax rates and transaction mechanics differ meaningfully. The analysis below breaks down both markets for international investors.

Quick answer

No DTT exists between Poland and Thailand, or between Poland and Cambodia - property income is taxable in both countries simultaneously
Polish abatement relief is capped at 1,360 PLN per year, making it largely symbolic for investors with meaningful rental yields
Transfer fee in Thailand is 2% of the government-appraised value, conventionally split 50/50 between buyer and seller
Withholding tax on property sales in Thailand is calculated progressively (5% to 35%), adjusted for the number of years of ownership
Specific Business Tax (SBT) in Thailand: 3.3% of the appraised or transaction value (whichever is higher), applies when the property is sold within 5 years of acquisition
Cambodia levies a 4% property transfer tax on purchase, plus an annual property tax of 0.1% on value exceeding 100 million KHR (approximately 25,000 USD)
Thailand's remittance rule was expanded from January 2024 - foreign income transferred to Thailand in any year (not only the year it was earned) is now subject to Thai personal income tax

Options and scenarios

Scenario 1: Buying a condominium in Thailand for 5 million THB

At a purchase price of 5,000,000 THB (approximately 580,000 USD equivalent in 2026), the transaction costs break down as follows:

Transfer fee (2%): 100,000 THB - conventionally split, so the buyer pays approximately 50,000 THB
Stamp duty (0.5%): 25,000 THB - paid by the buyer, but not charged when SBT applies
Specific Business Tax (3.3%): 165,000 THB - borne by the seller if the property is held for fewer than 5 years
Withholding tax: calculated progressively on the seller's gain; when purchasing a new unit from a developer, typically around 1% of the sale price (50,000 THB)

The buyer's total transaction cost is approximately 50,000 to 75,000 THB (1 to 1.5% of the purchase price). The seller bears the remaining charges.

Scenario 2: Renting out the same Bangkok condominium

With a monthly rent of 25,000 THB (annual gross income of 300,000 THB, roughly 35,000 PLN):

Thailand: rental income is subject to Thai personal income tax at rates from 0% to 35%. For a non-Thai-tax-resident who does not remit the income to Thailand in the tax year it is earned, no Thai tax liability formally arises under the remittance principle. However, if income is remitted or the investor qualifies as a Thai tax resident, Thai PIT applies.
Poland: a Polish tax resident must declare foreign rental income annually. Options include a flat-rate tax of 8.5% on income up to 100,000 PLN and 12.5% above that threshold, or the progressive general scale of 12% / 32%.
Abatement relief: even if tax was paid in Thailand, the deductible amount in Poland is capped at 1,360 PLN - a negligible offset for most investors.

Scenario 3: Buying an apartment in Phnom Penh for 120,000 USD

In Cambodia, foreign nationals can legally own units from the first floor upward in co-owned buildings (strata-titled condominiums). Key costs include:

Property transfer tax (4%): 4,800 USD - formally borne by the buyer
Annual property tax (0.1%): applied to value exceeding 100 million KHR (approximately 25,000 USD). On a 120,000 USD unit, the taxable base is roughly 95,000 USD, producing an annual tax of approximately 95 USD
Withholding tax on rental income: 14% for non-residents, typically withheld at source by the tenant or property manager
Poland: identical to the Thai scenario - no DTT, full declaration required in Poland, abatement relief capped at 1,360 PLN

Comparison table

Parameter	Thailand	Cambodia	Poland (investor obligations)
Property transfer tax / fee	2% of appraised value	4% of market value	N/A - local transfer tax only applies to Polish transactions
Specific Business Tax	3.3% (sale within 5 years)	Not applicable	No equivalent
Stamp duty	0.5% (not applied when SBT applies)	Included in transfer tax	Not applicable
Withholding tax on sale	5-35% progressive	4% of sale value	19% capital gains tax on profit
Rental income tax	0-35% PIT (remittance rule applies)	14% for non-residents	Flat 8.5/12.5% or progressive 12/32%
Annual property tax	0.02-0.3% (depends on use)	0.1% above threshold	No equivalent
DTT with Poland	None	None	Abatement relief capped at 1,360 PLN
Who pays transfer fee	Conventionally 50/50 split	Buyer	Not applicable

Risks and mistakes

1. Ignoring Polish tax obligations on foreign income. This is the most common error among Polish investors abroad. Even if rental income is never transferred to Poland, a Polish tax resident is legally required to declare it. The tax and penalty exposure can exceed the original tax liability many times over.

2. Assuming abatement relief eliminates double taxation. Following the 2021 amendment, the 1,360 PLN cap renders this relief largely ineffective. An investor earning 35,000 PLN annually in rental income will pay the full Polish tax rate minus 1,360 PLN - not an exemption, but a token deduction.

3. Confusing appraised value with purchase price in Thailand. Transfer fee and SBT in Thailand are calculated on the higher of the Land Department's appraised value or the transaction price. The appraised value is sometimes lower than market value, but the Land Department may challenge prices that appear artificially low.

4. Overlooking currency conversion costs. Buyers in Thailand must wire funds from abroad in a foreign currency and convert to THB through a Thai bank, obtaining a Foreign Exchange Transaction (FET) form. Bank spreads and conversion fees can add 1 to 2% to the effective transaction cost.

5. Pursuing risky ownership structures. Some investors consider purchasing through a Thai company to circumvent foreign ownership limits. This is a legally hazardous route - nominee shareholder structures are illegal in Thailand. In Cambodia, certain trust-like vehicles are more transparent but still require qualified legal counsel before use.

6. Relying on outdated information about the Thai remittance rule. From 1 January 2024, Thailand broadened the scope of its remittance rule: foreign-source income transferred to Thailand in any year - not just the year it was earned - is now potentially subject to Thai PIT. Interpretation guidance continues to evolve, and tax advice should reflect the current rules.

FAQ

Does Poland have a double taxation treaty with Thailand?

No. As of 2026, no double taxation treaty exists between Poland and Thailand. A Polish tax resident must report income from Thai property in both Thailand and Poland. The only partial relief available is the Polish domestic abatement mechanism, capped at 1,360 PLN per year.

How much is the transfer fee when buying property in Thailand?

The transfer fee is 2% of the government-appraised value set by the Land Department. Market convention splits this cost equally between buyer and seller, though the allocation can be negotiated and specified in the sale agreement.

Who pays Specific Business Tax in Thailand?

SBT of 3.3% - calculated on the higher of the appraised or transaction value - is borne by the seller, provided the property is sold within 5 years of acquisition. If the holding period exceeds 5 years, SBT does not apply and stamp duty of 0.5% is charged instead.

How is rental income from Cambodia taxed for a Polish investor?

In Cambodia, rental income earned by a non-resident is subject to 14% withholding tax, typically deducted at source. The Polish investor must additionally declare this income in Poland. With no DTT in place, the situation mirrors Thailand - double exposure with minimal relief, capped at 1,360 PLN.

Can I offset Thai taxes against my Polish income tax bill?

A proportional credit method is available under Polish domestic law for countries without a DTT. The abatement relief can then be applied on top, but it is capped at 1,360 PLN. In practice, the double taxation burden remains significant.

What is the annual property tax in Cambodia?

Cambodia levies an annual property tax of 0.1% on the portion of property value exceeding 100 million KHR (approximately 25,000 USD). For a unit valued at 120,000 USD, the taxable base is around 95,000 USD, producing an annual liability of approximately 95 USD.

Do I need to report a foreign property purchase to Polish tax authorities?

Yes. Polish tax residents holding assets abroad should include them in foreign asset disclosures. Rental or capital gains income must be reported on the relevant annual return (PIT-36 for general rules, or PIT-28 for the flat-rate option). Consulting a tax adviser with international expertise is strongly recommended.

What are the total buyer costs when purchasing in Cambodia?

The primary cost is the 4% property transfer tax payable by the buyer. Adding legal fees (typically 1,000 to 3,000 USD), due diligence costs, and any ancillary charges, the buyer's total transaction cost is approximately 5 to 6% of the property value. Agent commissions are usually borne by the seller at around 3%.

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Poland-Thailand Double Taxation: 7 Facts Every Investor Must Know in 2026