Poland-Thailand Double Taxation: 7 Key Facts for Property Investors in 2026

An international investor purchasing a condominium in Bangkok for 5 million THB may face between six and eight separate tax obligations, spanning two jurisdictions on opposite sides of the globe. Poland and Thailand have a double taxation treaty (in force since 1983, Journal of Laws 1983 No. 37, item 170), which sets out how to avoid taxing the same rental income twice. How the income is settled in the Polish PIT return should be confirmed with a tax adviser, because it affects net yield.

The good news is that legal mechanisms exist to reduce this dual burden. This article breaks down every tax and fee associated with buying, holding, and selling property in Thailand and Cambodia, from the perspective of a Polish tax resident investing in 2026.

Quick answer

• A double taxation treaty exists between Poland and Thailand (in force since 1983, Journal of Laws 1983 No. 37, item 170). Rental income earned in Thailand must also be declared in a Polish personal income tax return, and the treaty sets out how double taxation is avoided, confirm the method with a tax adviser.
• Transfer fee in Thailand is 2% of the official appraised value and is customarily split equally between buyer and seller.
• Withholding tax on property sales in Thailand is collected by the Land Department at the time of title transfer. The rate follows a progressive scale and depends on the number of years of ownership.
• No double taxation treaty exists between Poland and Cambodia (unlike Thailand).
• Property transfer tax in Cambodia is 4% of the market value, payable by the buyer.
• Annual property tax in Cambodia is 0.1% of the value exceeding 100 million KHR (approximately 25,000 USD).
• Rental income in Thailand is taxed at a progressive rate of 0 to 35%. In Cambodia, the rate is 14% corporate income tax for registered entities or 10% withholding tax on rental payments.

Options and scenarios

Scenario 1: Buying a Bangkok condominium for 5 million THB

At an approximate exchange rate of 1 THB to 0.12 PLN, this represents a purchase price of roughly 600,000 PLN.

Buyer-side transaction costs:

• Transfer fee (buyer's share): 1% of the official appraised value, approximately 50,000 THB
• Stamp duty: 0.5%, waived when Specific Business Tax applies
• Legal fees: 30,000 to 80,000 THB
• Sinking fund and common area fees: developer-dependent

Seller-side costs (relevant when reselling):

• Transfer fee (seller's share): 1%
• Specific Business Tax: 3.3% if the property is sold within 5 years of acquisition
• Withholding tax: progressive, based on years of ownership, at 5 million THB and 5 years of holding, this is approximately 75,000 to 150,000 THB

Total combined transaction cost across both buyer and seller: approximately 5 to 8% of property value.

Scenario 2: Buying an apartment in Phnom Penh for 120,000 USD

Buyer-side costs:

• Property transfer tax: 4% = 4,800 USD
• Notarial and registration fees: approximately 500 to 1,000 USD
• Legal counsel: 1,000 to 2,000 USD

Annual holding costs:

• Property tax: 0.1% of value above the 100 million KHR threshold. At 120,000 USD (approximately 490 million KHR), the taxable base after deducting the threshold is around 390 million KHR, resulting in an annual tax of approximately 390,000 KHR (roughly 95 USD).

Scenario 3: Rental income and double taxation in practice

A Polish investor rents out a Bangkok condo for 25,000 THB per month (approximately 3,000 PLN). Annual gross income: 300,000 THB.

In Thailand:

• Rental income is subject to progressive personal income tax at 0 to 35%. At 300,000 THB of annual income, the effective rate is approximately 5 to 10% after deductions and allowances.
• Thai tax liability: approximately 15,000 to 30,000 THB.

In Poland (PIT for 2026):

• Private rental income may be taxed as a lump sum: 8.5% up to 100,000 PLN, 12.5% above that threshold.
• Under general principles: progressive rates of 12% and 32%.
• Because Poland and Thailand have a double taxation treaty, the way Thai tax paid is taken into account in the Polish return follows the treaty and Polish PIT rules, confirm the method with a tax adviser.
• The rental income must still be declared in Poland, and the treaty sets out how double taxation is avoided.

For investors considering Cambodia alongside Thailand, the position is different, no treaty protection exists between Poland and Cambodia, and the Polish relief cap applies.

Comparison table

Parameter	Thailand	Cambodia	Notes for International Investors
Transfer fee at purchase	2% (split 50/50)	4% (paid by buyer)	Higher entry cost in Cambodia
Specific Business Tax	3.3% (sale within 5 years)	None	Thailand rewards holding beyond 5 years
Stamp duty	0.5% (when SBT not applicable)	0.1% (registration fees)	In Thailand, SBT replaces stamp duty
Annual property tax	0.02-0.3% (by property type)	0.1% above threshold	Thailand's Land and Building Tax introduced 2020
Rental income tax (local)	0-35% (progressive PIT)	10-14% (WHT or CIT)	Effective Thai rate often lower in practice
Double taxation treaty with Poland	Yes (since 1983)	None	Confirm the settlement method with a tax adviser
Settlement currency	THB	USD/KHR	Cambodia is de facto dollarized

Risks and mistakes

1. Ignoring Polish tax obligations. Even after paying tax in Bangkok, a Polish tax resident must file a return in Poland and declare foreign income. Failure to do so carries the risk of criminal tax proceedings.

2. Assuming the 'abolicja' relief eliminates double taxation. Since 2021, this relief has been subject to a strict annual cap. For rental income from a country with no Polish tax treaty, the real saving is only around 1,360 PLN per year. It does not eliminate double taxation, it merely softens it.

3. Confusing official appraised value with market price in Thailand. The Land Department applies its own valuation, which is often lower than the transaction price. Transfer fees and withholding tax are calculated on whichever value is higher, the official appraisal or the declared sale price.

4. Operating without a legal structure in Cambodia. For investors planning to rent commercially, using a local LLC structure in Cambodia may be more tax-efficient than renting as a private individual. Without proper legal analysis, investors risk overpaying tax unnecessarily.

5. Overlooking currency conversion costs. Transferring funds from THB or USD to PLN generates a banking spread of 1 to 3%. This is a real, recurring cost that reduces net returns and should be factored into yield projections.

6. Selling within 5 years in Thailand. The 3.3% Specific Business Tax is added on top of withholding tax. The total tax burden on a quick resale can reach 6 to 8% of the property value, a significant hit to capital gains.

7. Failing to retain documentation of foreign tax paid. Polish tax authorities require proof that tax was paid abroad. Without a foreign tax certificate and payment confirmation, the proportional credit may be disallowed during an audit.

FAQ

Does Poland have a double taxation treaty with Thailand?

Yes. Poland and Thailand have a double taxation treaty in force since 1983 (Journal of Laws 1983 No. 37, item 170). Income from Thai property may be taxable in both countries, and the treaty sets out how double taxation is avoided.

What is the transfer fee when buying property in Thailand?

The transfer fee is 2% of the Land Department's official appraised value. It is customarily split equally between buyer and seller, though the split can be negotiated contractually.

Who pays the property transfer tax in Cambodia?

The buyer pays. The transfer tax in Cambodia is 4% of the market value of the property, one of the higher transfer tax rates in Southeast Asia.

How should rental income from Thailand be reported in a Polish tax return?

It must be declared in the annual Polish PIT return. How Thai tax is taken into account follows the Poland-Thailand double taxation treaty and Polish PIT rules. Consultation with a tax adviser experienced in cross-border income is strongly recommended.

Is there an annual property tax in Cambodia?

Yes. Cambodia levies an annual property tax of 0.1% on the value exceeding 100 million KHR (approximately 25,000 USD). For a typical 120,000 USD apartment, the annual liability is around 95 USD.

What is Specific Business Tax in Thailand?

Specific Business Tax (SBT) is a 3.3% tax levied on the seller when property is sold within 5 years of acquisition. After 5 years, SBT no longer applies and is replaced by the lower stamp duty rate of 0.5%.

What are the total purchase costs for a foreign buyer in Thailand?

Buyer-side transaction costs typically amount to 1.5 to 3% of the property value, covering the buyer's share of the transfer fee, legal fees, and due diligence. Seller-side costs on resale can reach 4 to 8% depending on the holding period.

Can Thai tax paid be offset against Polish income tax?

The way Thai tax is offset against Polish PIT follows the Poland-Thailand double taxation treaty and Polish PIT rules, so confirm the method with a tax adviser before filing.

Is it better to hold Cambodian property through a company?

For investors focused on commercial rental, a Cambodian LLC structure may be more tax-efficient. The corporate income tax rate is 20%, but it allows deduction of operating expenses. This decision requires individual legal and tax analysis before structuring.

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

Yes. Polish tax residents have disclosure obligations. Foreign property holdings must be considered in the context of controlled foreign company (CFC) rules and the requirement to report foreign income in the annual personal tax return.

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