From our review of your management fee in view of Thai’s Revenue Code, we can conclude as follows:-
1) Corporate Income Tax for Service Provider - If the service provided by the Service Provider related to managerial and operational activities, which are treated as business profits thus no withholding income tax is involved upon payment made to the party located in Switzerland.
2) VAT for payment of fee to Service Provider - 7% VAT should be submitted upon payment of service fee by using Por Por 36, since this is treated as service is provided outside Thailand and is used in Thailand.
3) Duty stamp for employment contract - there must be an affix of duty stamp at the rate of Baht 1 for each Baht 1,000 fee, by fixing at the original agreement when it is firstly brought into Thailand and using estimating fees to be paid during the agreement period.
4) Tax deductible expenses for Thai company under Revenue Code - This type of payment is treated as tax deductible expenses since it is not calculated on from net operating income of Int. Thailand.
Best regards,
Kriengsak M.