Corporate Taxation in Thailand: A Guide for Foreign Companies

Navigating Thailand’s tax landscape can be challenging for foreign companies.

Understanding local corporate and indirect tax requirements is essential to remain compliant, manage tax exposures, and avoid penalties.

Our accounting & tax team provides comprehensive corporate tax advisory and compliance services, helping international businesses understand deadlines, audit procedures, and current regulatory requirements.

Corporate Income Tax

Corporate Income Tax (CIT) in Thailand is levied on juristic entities conducting business or earning income in Thailand, whether locally incorporated or foreign companies with Thai-sourced income. 

Resident companies (incorporated in Thailand) are taxed on worldwide income at the standard CIT rate of 20%, with taxable profits determined from audited financial statements, adjusted as required under Thai Accounting Standards (TAS) and the Revenue Code. Non-resident companies are taxed on Thai-sourced income only.

Branches of foreign companies face a 10% profit remittance tax, treated as deemed dividends. Branches are not considered Thai tax residents and therefore cannot access benefits under Thailand’s Double Taxation Agreements (DTA)

The corporate tax year typically aligns with a company’s accounting period, which must not exceed 12 months. Half-year provisional CIT returns must be submitted, and underpayment or underestimation may result in surcharges up to 20%.

Value Added Tax

VAT is an indirect tax on the supply of goods and services and on imports. Companies with an annual turnover exceeding THB 1.8 million must register for VAT.

VAT is charged at 7% on taxable goods and services, while exports are zero-rated. Foreign suppliers providing VAT-able services in Thailand may be subject to reverse charge VAT, where the payer remits VAT on behalf of the supplier. VAT compliance is governed by the Thai Revenue Code and must be filed using the appropriate forms (PP 30 for registered taxpayers, PP 36 for reverse-charge cases).

Withholding Tax

Certain payments to resident and non-resident companies are subject to WHT at source. WHT rates depend on the type of income and the recipient’s tax status (e.g., 3% for professional fees, 5% for services from foreign entities without a Thai branch, 10% on dividends, 0–35% on salaries). Payments to non-residents from non-DTT countries are typically subject to 15% WHT, but rates may be reduced under applicable Double Tax Treaties.

Withholding tax is credited against the recipient’s corporate tax liability, and returns are filed via forms such as PND 53 (residents) or PND 54 (non-residents).

Capital Gains and Stamp Duty

Capital gains are generally treated as assessable income for CIT purposes; Thailand does not impose a separate capital gains tax. Stamp Duty applies to certain official documents, including leases, share transfers, debentures, and hire-of-work contracts. Rates and filing requirements are specified in the Thai Revenue Code, with non-compliance subject to penalties.

Tax Filing and Payment

Thailand operates a self-assessment tax system.

  • Annual CIT returns are due within 150 days after the end of the accounting period.
  • Half-year provisional returns must be filed based on estimated or actual first-half profits.
  • Tax payments are generally made twice a year: at the half-year and year-end filing points.

Transfer Pricing and Related Party Transactions

The Thai Revenue Department (TRD) requires that related-party transactions comply with arm’s length principles. Companies with revenues exceeding THB 200 million and related-party transactions must submit year-end related-party disclosure forms. Non-compliance or insufficient documentation may result in adjusted taxable income plus fines up to THB 200,000 per case.

Double Taxation Agreements (DTA)

Thailand has signed DTA with multiple countries to prevent double taxation. DTA can reduce withholding tax rates on dividends, interest, and royalties. Non-treaty countries are generally subject to default WHT rates of 10% on dividends, 15% on interest and royalties.