Note: The amount of revenue subject to corporate income tax reduction must not be more than revenue subject to corporate income tax exemption according to item 1.1 and 1.2.
Personal Income Tax Personal income tax for expatriates at the specialist or executive level working in an IHQ is reduced to 15%.
Specific Business Tax Exemption for the revenue from lending to associated enterprises
Withholding Tax Exemption for the following revenue:
- Dividends paid by the IHQ (dividends paid from revenue subject to corporate income tax exemption) to corporate shareholders in foreign countries
- Interest paid by the IHQ (interest from loans taken out by an IHQ to relend to associated enterprises under its corporate treasury center) to corporate lenders in foreign countries
Conditions to apply for privileges offered by the Revenue Department:
- Must supervise foreign branch offices or associated enterprises in not less than one country.
- Paid-up registered capital must not be less than THB10 million on the last day of each accounting period.
- Total business spending (sales and administration expenses) must not be less than THB15 million per year in Thailand.
Note: If the IHQ is unable to meet any of the specified conditions within an accounting period, the tax incentives in that year will not be granted.
International Trade Center (ITC) projects receive the following incentives:
Incentives offered by the Board of Investment (BOI)
• Permission to bring in skilled personnel and experts into the Kingdom to work in investment promoted activities.
• Permission to own land
• Exemption of import duty on machinery
• Exemption of import duty on raw materials and parts for export purpose
Conditions to apply for privileges offered by the BOI
- An ITC must have paid-up registered capital of not be less than THB10 million.
Incentives offered by Revenue Department (RD)
Corporate Income Tax (CIT)
For 15 accounting periods from the date of approval by the Director General of the Revenue Department, an ITC is entitled to corporate income tax exemption on:
1. Revenue received from the purchase and sale of goods overseas 1) without importing goods into Thailand or 2) that are imported into Thailand through border crossing or transshipment according to customs laws.
2. Revenue from providing services in relation to foreign trade to juristic persons established under foreign laws or revenue received overseas or generated overseas.
Personal Income Tax
Personal income tax for expatriates at the specialist or executive level working in an ITC is reduced to 15%.
Conditions to apply for privileges offered by the Revenue Department:
- Paid-up registered capital must not be less than THB10 million on the last day of each accounting period.
- ITC must have total business spending (sales and administration expenses) of at least THB15 million per year in Thailand.
Note: If the ITC is unable to meet either one of the specified conditions within an accounting period, the tax incentives in that year will not be granted.
In addition, to facilitate IHQ/ITC registration for a foreign business license, the Department of Business Development, Ministry of Commerce, has reduced the timeframe as follows:
• 30 days to 15 days for BOI-promoted companies
• 60 days to 30 days for non-BOI promoted companies
Last Updated: July 2015