-in case of carriage of goods three percent of freight charges fees and other benefits whether chargeable in Thailand or not
it should be noted that if a foreign company which carries on international transportation business in Thailand as aforesaid has other income such as interest that other income will be subject to CIT on net profits basis
fourthly if a foreign company does not carry on business in Thailand but receiving income under section 40 (2) (3) (4) (5) or (6) of the revenue code which is paid from or in Thailand it shall be subject to pay CIT for example a foreign company which does not have any branch an agent or an employee in Thailand lent money to a company in Thailand was considered not to be carried on business in Thailand the tax rate is 15 per cent of the gross income except dividend which is subject to 10 per cent rate this makes the effective tax rate from investing in Thailand stands at 28 per cent (assuming that the corporate income tax rate is 20 per cent)