Doing Business inThailand 2022

www.pwc.com/thContents
Foreword ............................................................................ 3
Chapter 1: Thailand at a glance ......................................... 5
Chapter 2: EEC, Thailand’s gateway to Asia ...................... 14
Chapter 3: Business taxation ............................................. 20
About PwC ......................................................................... 42
Contacts ............................................................................. 46

PwC l Doing Business in Thailand 20222

Foreword
Welcome to the 2022 edition of our Doing Business in Thailand. Over the past
decades, Thailand has made impressive progress in modernising its economy,transforming into a competitive developing country with a strong urban centre.
Economic success was contributed by its robust tourism, agricultural, export andelectronics industries.
Although these accomplishments have propelled a new stage of economic
development, it also brought a new set of challenges, to escape the middle-income
trap.
In the past few years, the government and public sector have been working hardto build on the country’s strategic position as a regional business hub in the heartof Southeast Asia. This makes it an ideal location for entrepreneurs seeking accessto Thailand’s domestic market of 70 million people while also leveraging its tradeinfrastructure to reach the fast-growing CLMV (Cambodia, Laos, Myanmar andVietnam) markets and economic giants such as China and India.
To further provide an attractive business climate for foreign investors seeking to
do business in Thailand, the government has been continuously developing its
Eastern Economic Corridor (EEC) initiatives to revitalise the country’s easternseaboard while also driving a signiﬁcant transformation to the economy.
Three eastern provinces have received support from the private sector andincentives from the Thai government. The private sector and foreign investment
are key to creating growth and technological development in Southeast Asia’s
second-largest economy.
In this Guide, we help those who are interested in doing business in Thailand byproviding an overview of the country’s business landscape, the EEC and importantbusiness taxation. The coverage of the subjects is not exhaustive but is intended
to deal with some of the more important and/or broad questions that may arise.
Chanchai Chaiprasit
Chief Executive Ofﬁcer
PwC Thailand

PwC l Doing Business in Thailand 20223

Disclaimer
This Guide is not intended to serve
as legal or taxation advice, but rather
provide general information forinvestors to understand key facts about
Thailand. It is also important to note thatcertain incentives, regulations andtaxation are subject to change.

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Chapter 1:
Thailand at a glanceCountry Overview
Total land size

Population

513,120 km²

71 million

Currency

GDP per capita

Thai Baht

USD7,233 (2021)

GDP growth

Headline inﬂation

2.5% (June 2022)

7.66% (June 2022)

Logistics

Ranked 2nd in ASEAN after
Singapore, 7th in Asia according
to the World Bank’s Logistics
Performance Index 2018

Sources: Bank of Thailand (BOT), Ofﬁce of the National Economic and Social Development Council (NESDC), United Nations
Population Fund (UNFPA) and World BankPwC l Doing Business in Thailand 2022

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Foreign direct
investment
netﬂow(2017 - 2021)

FDI (USD million)
16,000.00
14,000.00

13,186.33
12,156.21

12,000.00
10,000.00
8,285.17

8,000.00
6,000.00

4,790.36

4,000.00
2,000.00
0.00

Year

2017

-2,000.00

2018

2019

2020

2021

-4,000.00-4,845.36-6,000.00

Source: World Bank

GDP by sector

Thailand’s GDP by sector H1 2022
Agriculture

9%Services

Industrial

58%

33%

Agriculture
Industrial
Services

Source: National Statistical Ofﬁce of Thailand (NSO)

Unemployment rate (Q1 2020 - Q2 2022)
1000

2.5

900
2

800
700
600

1.5

500
400

1

300
200

0.5

100
0

0
Q1 2020

Q2 2020

Q3 2020

Q4 2020

Q1 2021

Q2 2021

Q3 2021

Q4 2021

Number of Unemployment (Thousands)

Q1 2022

Q2 2022
Unemployment (%)

Source: Ofﬁce of the National Economic and Social Development Council (NESDC)PwC l Doing Business in Thailand 2022

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TradeThailand has a broad range of trading partners and its external trade remain
resilient in the midst of the pandemic.
Top ﬁve trading partners (January - August 2022)

2

1China

USD72,579m

United States
USD43,866m

5

United ArabEmirates

3 Japan

USD40,409m

USD15,042m

4 Malaysia

USD18,854m

Source: Ofﬁce of the Permanent Secretary Ministry of Commerce

Thailand is also one of the most open economies in the world. To date, it has 14
trade agreements in effect with 18 countries and territories.
ASEAN Free Trade Area (AFTA) /ASEAN Economic Community (AEC)
ASEAN - China

Thailand - Japan
Thailand - India

ASEAN - India
ASEAN - Japan
Thailand - Peru

Thailand - Australia

ASEAN - South Korea

Thailand - New ZealandThailand - Chile
ASEAN - Australia - New Zealand

ASEAN - Hong Kong SAR

RCEPRegional Comprehensive Economic Partnership

Source: Department of Foreign Trade (DFT), Ministry of Commerce

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Unrivalled location
North

Located at the centre of Southeast
Asia, acting as a crossroad of tradeand maritime routes, Thailand shares
its borders with Cambodia, Laos,
Myanmar and Malaysia.
CentralNorth-East

West

East

South

The country has a total area of
513,120 km² and is divided into six
regions – north, northeast, central,
west, east and south. The ofﬁcial
population is approximately 71 million
with Thai being the predominant ethnic
group and minorities including Chinese,
Malays and Cambodians, as well asother indigenous peoples.
Its strategic location positions thecountry as an important regional
producer and a key driver of intraregional trade and connectivity,
especially to CLMV countries and thehigh-end markets of east Asia.

Thailand is well-connected to major
cities in Asia – within less than ﬁvehours ﬂight from its capital Bangkok
to Beijing in China and 2.5 hours toHong Kong SAR.
In the past years, the country has
been supported by the public andprivate sectors in contributing trades
and investments. Despite a decline
in 2020 due to COVID-19, Thailand’s
2021 exports rose 17% with value
accounting for USD271bn. Suchstrong expansion is attributed toimport acceleration from many
trading partners.

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Political structure
Thailand is a constitutional monarchy with the monarchserving as the head of state while the prime minister isthe head of the government. Although the country has
gone through 17 constitutions since 1932, the basic
structure of the government remains unchanged.
The government is composed of three branches: theexecutive, legislative and judiciary.
The House of Representatives consists of 500 elected
members and together with 250 Senators appointed
by the Royal Thai Army, forms the National Assemblyof Thailand (also known as the Parliament). The
constitution allows the parliament to enact and passlaws.
Meanwhile, the executive branch is led by the cabinet
which consists of ministers with the prime minister as
the leader. This branch of the government handles
administration and management of various government
agencies.

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The digital economy
In the past decade, Thailand has made good progress in its transformation into
the digital economy. Digital infrastructure has improved greatly and the entire
population is able to access the internet and digital content. Thailand’s e-commerceis one of the fastest growing business sectors in Southeast Asia, with 68% growthin 2021 and a further 14% growth per annum forecast to 2025.
+14%

Thailand’s e-commerce set to surge(Gross online merchandise value: GMV per USD billion)

35
+68%
21

12
5
2019

2020

2021

2025
Source: e-Conomy SEA 2021 report

Thailand experienced an increase of 9 million digital users
since the start of the pandemic with 67% of the new users
living in non-metro areas, according to the e-Conomy SEA
2021 Report. Consumption penetration was ranked second
highest in Southeast Asia after Singapore, with 90% of internet
users consuming digital services. Thai users showed no signof stopping and 98% intend to continue to use the service.

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The evolving ESG
ecosystem
Climate change is one of the biggest challenges
facing our world today. In line with the pledges
made by most countries who are concerned about
this issue, Thailand pledged to reduce carbon
emissions to achieve carbon neutrality by 2050 andnet-zero greenhouse gas emissions by 2065 at lastyear’s 26th session of the Conference of the Parties(COP 26) in Glasgow, Scotland.
Under this commitment, the government has set its
sustainable development roadmap consisting of
three pillars: (1) long-term reduction of greenhousegas in line with environmental, social and governance(ESG) developments (2) adaptation to mitigate
climate change impacts and (3) supporting
investments in climate-friendly public and private
infrastructure as well as the development of
economic, ﬁnancial and ﬁscal measures toincentivise relevant sectors.

Steering the economy on a sustainable path
To execute the sustainable plan, government agencies have formulated policies forthe industrial and service sectors to conduct eco-friendly business practices anddrive sustainable growth. These measures include carbon tax research initiatives
on goods and services that emit high levels of greenhouse gas. The study is
expected to be completed with clear guidelines and tax rates in 2023. Anothernotable plan is the electric vehicle (EV) roadmap, which is driven by the 30/30 policy
to produce zero emission vehicles (ZEV) that will account for 30% of all vehicle
production by 2030. At the same time, the government plans to increase 55% ofurban green space by 2037.
In addition, the government has adopted its national strategy to drive the country’s
economy forward with the 2021–2026 BCG model (Bio-Circular-Green Economy
Model) as a major mechanism for balancing business growth with eco-friendly
practices. It’s also intended to introduce green ﬁnancial measures to drive
investments in innovation and green business.

Sources: Bangkok Post, The Bank of Thailand (BOT), The Nation, The Secretariat of the Prime Minister, Government House and
The Stock Exchange of Thailand (SET)PwC l Doing Business in Thailand 2022

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The private sector’s role in sustainability goals
To promote an eco-friendly business environment, the government has introduced
green ﬁnancial measures to drive green innovation and business investments.
Thailand’s private sector is also working to ﬁnd ways to fulﬁl its sustainability
commitments with regulators introducing ESG measures in markets.
The Securities and Exchange Commission (SEC) laid out its Corporate Governance
Code that requires sustainability reporting from listed companies. Although there’s
ﬂexibility around the choices for reporting frameworks, the Stock Exchange ofThailand (SET) follows the Global Reporting Initiative, which is the most commonlyused guidance.
From 2022, all public companies must disclose their ESG performance through their56-1 One Report, effective from the ﬁnancial period ending 31 December 2021.
In November 2021, the SET also became a supporter of the Task Force on
Climate-related Financial Disclosures (TCFD), which sets the standards foraddressing environmental issues.
Earlier that year, the Bank of Thailand (BOT) announced an improvement to its
supervisory review process under Pillar 2, which includes incorporating ESG in therisk analysis of funds. This move is a sign the central bank is interested in holding
all of the banks in Thailand accountable for ESG reporting on risk management.
While some of the private sector is already actively engaged in ESG practices,
importantly, most large listed companies understand the importance of ESG. Many
have announced their sustainability goals and strategic plans while incorporating
into their risk management practices. ESG adoption by corporations is a criticalresponse to the unpredictable nature of environmental scenarios, and will help toprovide clarity to our efforts to address the crisis.

Sources: Bangkok Post, The Bank of Thailand (BOT), The Nation, The Secretariat of
the Prime Minister, Government House and The Stock Exchange of Thailand (SET)PwC l Doing Business in Thailand 2022

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Chapter 2:
EEC, Thailand’s gateway
to Asia

The EEC ﬂagship project
Often called the ‘gateway into Asia’, the Eastern Economic Corridor (EEC) projectis a government initiative that began in 2017 to revitalise Thailand’s easternseaboard by turning areas in the provinces of Rayong, Chonburi and Chachoengsao
into special economic zones with investment incentives to draw FDI. Besides
foreign investment, the zones are also for future technological advancement toencourage Thailand to spearhead new innovations that upgrade life and well-being.
So far, the EEC spans three provinces, collectively occupying an area of 13,266 km².
Don Mueang
International Airport

Suvarnabhumi
International Airport
Ladkrabang
Station

Chachoengsao
Station

Chachoengsao

Chonburi
StationChonburi
Laem Chabang
Port

Si Racha
StationPattayaStationRayongU-Tapao
StationRayongStationSattahipCommercial Port

U-Tapao
Airport
Map Ta Phut
Industrial Port

Source: The Eastern Economic Corridor Ofﬁce of Thailand (EECO)

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Currently, the EEC’s
12 targeted industries are:

The ﬁrst ﬁve S-curve industries
Advanced agriculture and biotechnology• Precision agriculture• Bio-reﬁnery and bio-extraction• Post-harvest management• Gene editing for plants and animals

Food for the future• Nutrition and supplements• Functional food
• Novel food and plant-based food• Flavours and fragranceIntelligent electronics
High-value and medical tourism• Smart appliances• Microelectronics design• 5G component manufacturing• Medical and wellness tourism• MICE and mega events

Next-generation automotive• Electric vehicles (EV)• Autonomous vehicles (AV)The seven new S-curve industries
Defence• Import substitution• Maintenance• Disaster management

Education and humanresources development• International universities• Certiﬁcation bodies for professional skills• EduTech

Digital• Software and platform• Artiﬁcial intelligence (AI)• Big data and advanced analytics• Digital infrastructure• Cloud (laaS) and data centre• Cybersecurity

Biofuel and biochemical• Speciality materials (bioplastics)• Biochemical (fatty acids,
oleochemicals, lactic acids)• Biofuel (bioethanol, biodiesel)

Aviation and logistics• Aviation• Maintenance repair andoverhaul (MRO)• OEM for aircraft and parts• Ground service equipment• Logistics• High-value logistics• Smart logistics solutions

Medical and comprehensive
healthcare• Next-gen health therapy• Precision medicine and biopharma• Regenerative medicine and advanced
cosmeceuticals• Pharmaceuticals and biopharmaceuticals• Medical devices• Digital health

Automation and robotics• Industrial robots• Service robots• System integrator

Source: The Eastern Economic Corridor Ofﬁce of Thailand (EECO)

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Entering 2022, Phase I (EEC investment target) is now complete, attracting THB1.7tn(USD50bn) of capital. Four Public and Private Partnership (PPP) infrastructure
projects worth THB654,921m (USD19bn) were signed: high-speed rail linking three
airports, U-Tapao International Airport, Laem Chabang Port Phase III and Map Ta
Phut Industrial Port Phase III.

U-Tapao International Airport
Part of Bangkok’s airport system, and linked to Bangkok by high-speed
rail. The target is 60 million passengers per year. The airport is expected
to commence operation in 2025.

High-speed rail linking three airports
High-speed rail and airport rail link extension will enhance connectivity
in ﬁve provinces with nine new stations that link the three international
airports in the greater Bangkok area: Don Mueang, Suvarnabhumi,
and U-Tapao. The high-speed train is set to begin operation in 2025.

Map Ta Phut Industrial Port Phase III
The port’s capacity will increase up to 19 million tonnes per year to
create Southeast Asia’s shipment hub when it goes into operation in2026.

Laem Chabang Port Phase III
The port will install an automated system to become the foundation
for a regional logistics centre, expanding capacity to 18 million TEUs
(20-foot equivalent units) and three million vehicles per year. This port
will be ready for operation in 2025.

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EEC tax incentives
An EEC project will be promoted only if it’s engaged in one of the target industries,
such as smart electronics, automotive, automation and robots, aviation and digitaltechnology. An EEC promoted company will be granted corporate income tax
exemption and/or reduction privileges for up to 13 years by virtue of the investment
promotion law.
The Ofﬁce of the Board of Investment of Thailand (BOI) has issued the criteria andincentives for promoted activities located in the EEC. The tax incentives are
categorised under the following zones:• Special industry promotion zones- Eastern Airport City (EECa)- Eastern Economic Corridor of Innovation (EECi)- Digital Park Thailand (EECd)- Medical Hub Thammasat University (Pattaya) (EECmd)- Genomics Thailand (EECg)• Industrial estate or industrial area within the EEC
Only investors in eligible activities that have been granted tax incentives for ﬁve or
more years (except for those speciﬁed in a negative list), targeted core technologies
and enabling services, can apply for the incentives granted under the EEC policy.
Applications must be submitted before 30 December 2022, except for those under
the special industry promotion zone for which there is no due date.

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Tax incentives provided by the
BOI:• BOI standard incentives• Additional CIT exemption up to two years forcertain activities• CIT reduction of 50% for three years after the endof the tax holiday
However, the EEC incentives cannot be used
together with those under the merit for industrial
area development.
The EEC Act also grants a personal income tax
reduction for experts with special knowledge/ability
who work or operate a business in certain zones
within the EEC.
Qualiﬁed expatriate and Thai employees are allowed
a ﬂat rate of 17% personal income tax on theirincome derived from working for companies carrying
on target activities within the EEC.

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Chapter 3:
Business taxation

Rates of tax and due dates
Corporate income tax (CIT) rates
Headline CIT rate (%)

20

Corporate income tax (CIT) due dates
CIT return due dateWithin 150 days from the closing date of the accounting period.

CIT ﬁnal payment due
dateWithin 150 days from the closing date of the accounting period.

CIT estimated payment
due dates

Within two months after the end of the ﬁrst six months of theaccounting period.

Personal income tax (PIT) rates
Headline CIT rate (%)

0 - 35

Personal income tax (PIT) due dates
PIT return due date

31 March

PIT ﬁnal payment
due date

31 March

PIT estimatedpayment due dates

Not applicable (except for certain business income)Value-added tax (VAT) rates
Standard VAT rate (%)

7 reduced from the standard 10% rate until 30 September 2023
(unless further extended by the government).

Withholding tax (WHT) rates
WHT rates (%)(Dividends/Interest/
Royalties)

Residents: 10 / 1 / 3
Non-residents: 10 / 15 / 15

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Capital gains tax (CGT) rates
Headline corporate
CGT rate (%)

Capital gains are subject to the normal CIT rate.

Headline individual
CGT rate (%)

Capital gains are subject to the normal PIT rate.

Net wealth/worth tax rates
Headline net wealth/worth tax rate (%)

Not applicable

Inheritance and gift tax rates
Headline inheritancetax rate (%)

10

Headline gift tax
rate (%)

5

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Signiﬁcant developments
Thailand signed the Multilateral Instrument in December 2021 and submitted its
instrument of ratiﬁcation in April 2022. The Multilateral Instrument became effectivefrom 1 July 2022.

Taxes on corporate income
Companies incorporated in Thailand aretaxed on worldwide income. A company
incorporated abroad is taxed on its proﬁts
arising from or in consequence of thebusinesson in Thailand. The
Doncarried
MueangInternation Airport
corporate income tax (CIT) rate is 20%.
A foreign company not carrying on
business in Thailand is subject to a ﬁnal
withholding tax (WHT) on certain typesof assessable income (e.g., interest,
dividends, royalties, rentals, and service
fees) paid from or in Thailand. The rateof tax is generally 15%, and 10% fordividends, while other rates may apply
under the provisions of a double tax
treaty (DTT).

Petroleum tax
International oil companies can engage
in exploration and production activitiesin Thailand under a concession, aproduction sharing contract, or a service
contract.
Taxation on income from petroleum
operations is imposed on petroleum
concessionaire companies andproduction sharing producers by thePetroleum Income Tax Acts (PITA).
Petroleum companies under a service
contract are not taxed under PITA but
under the Revenue Code.

Companies and juristic partnerships
with paid-in capital not exceeding
THB5m at the end of any accounting
period and income from the sale ofgoods and/or the provision of services
not exceeding THB30m, i.e., small andmedium enterprises (SME) are subject
to reduced rates, e.g. 15% for net proﬁts
between THB300k and THB3m.

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Corporate residence
Corporate residence is determined by the place of incorporation so a company
incorporated under the laws of Thailand is a resident company.
A company incorporated abroad is subject to CIT in Thailand if it is considered tobe carrying on business in Thailand. The term ‘carrying on business in Thailand’ isbroad and, subject to the provisions of a DTT, includes the presence of an
employee, representative, or go-between that results in the foreign company
deriving income or gains in Thailand.

Withholding tax
A company, juristic partnership, or other juristic person, which pays assessable
income to another Thai company, juristic partnership, other juristic person or aforeign company carrying on business in Thailand (through a branch or permanentestablishment) must withhold tax from domestic payments such as royalties at
3%, interest at 1%, professional services and hire of work at 3%.

Foreign tax credit
A Thai company can use foreign tax paid on business income or dividends as acredit against its CIT liability. However, the credit cannot exceed the amount ofThai tax on the income. Credit is also given for any Thai tax that has been withheld
at source (as noted above) and for the half-year tax paid.

Withholding tax on foreign
payments

Double tax treaties

Thailand has concluded tax treaties with
A ﬁnal withholding tax is imposed on the 61 countries.
remittance of income to foreigncompanies not carrying on business inThailand in respect of the following:
Brokerage, fees for services

15%

Royalties

15%

Interest

15%

Dividends

10%

Capital gains

15%

Rental of property

15%

Liberal professions

15%

The above taxes may be reduced or
exempt under double tax treaties.
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Other taxes
Carrying on business in Thailand is subject to othervarious taxes other than CIT. Key taxes are
summarised below. Other types of taxes to note,other than those stated below include customs
duties, excise tax, property taxes, etc.

Value-added tax (VAT)
The standard VAT rate is 10%, but therate has been reduced to 7% until 30
September 2023 (unless further extended
by the government).
VAT is levied on the sale of goods and theprovision of services. Exports are zero-rated,while a number of goods and services are
exempt (e.g., basic groceries, education,
healthcare, interest, leasing of immovable
property, sale of real estate).
Non-resident electronic service providers
and electronic platform operators, whoreceive income of more than THB1.8m per
year from providing electronic services tonon-VAT registered customers in Thailand,
must register for VAT, ﬁle VAT returns, andpay VAT (without deducting input tax) via
the Revenue Department’s online system.
These taxpayers aren’t required to issue
tax invoices or prepare input tax reports.

Key conditions for VAT collection:

Digital services areprovided from abroad.

PwC l Doing Business in Thailand 2022

Services are provided byelectronic means and areused by a customerin Thailand.

The customer inThailand is not a
VAT registrant.

25

Speciﬁc business tax
Speciﬁc business tax is collected at ﬁxed rates on the gross revenue ofcertain businesses not subject to VAT, such as commercial banks, similar
ﬁnancial businesses, and the sale of immovable property, taxed at 3%,
and life insurance, taxed at 2.5%. The speciﬁc business tax rate has been
reduced to 0.01% for certain revenue derived by commercial banks, andﬁnance, securities, and credit foncier businesses, as well as businesses
with regular transactions similar to commercial banking.
An additional 10% of the tax is levied as municipality tax.

Stamp duty
Stamp duty is levied on 28 different types of documents and instruments,
including contracts for hire of work, loans, share transfers, leases of landor buildings, and insurance policies. The stamp duty rate depends on thetype of document and ranges from THB1 per THB1,000 of value on mostcontracts and agreements to a ﬁxed amount per instrument on mostcommercial and other documents.
Most instruments subject to stamp duty in the form of e-instruments are
required to be ﬁled and have the stamp duty paid in cash via the internet.
In this case, the ﬁling of the return and payment can be made before theexecution of the instrument or within 15 days from the date following thaton which the instrument was executed.
Failure to pay the stamp duty and afﬁx the stamps on time is subject to asurcharge ranging from 200% to 600% of the duty payable. Unstamped
documents or instruments are not admissible as evidence in a civil lawsuit.

Capital tax
There are no capital taxes in Thailand.

Payroll tax
An employer is responsible for withholding PIT from all salaries andbeneﬁts paid to or on behalf of an employee and remitting such tax to the
Revenue Department within seven days from the end of the month inwhich the salaries and beneﬁts were paid.

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Branch income
Branches of foreign corporations are subject to
CIT on locally earned proﬁts only. Branch proﬁts
remitted to the foreign head ofﬁce are subject toan additional tax at the rate of 10%. However,this is a tax on the disposition of proﬁts abroad
and is not limited to remittances. For example,
a credit of proﬁt to the head ofﬁce account in thebooks is held to be a disposition of proﬁt abroad
even though no remittance of funds has takenplace.

Income determination
Capital gains
There is no speciﬁc legislation governing capital gains. Except as noted
below, all capital gains earned by a Thai company are treated as ordinary
revenue for tax purposes. Capital gains on the sale of investments
derived from or in Thailand by a foreign company not carrying on
business in Thailand are subject to a tax of 15%, withheld at source by
the purchaser, unless otherwise exempt under a DTT.
The following gains earned by a foreign company not carrying on businessin Thailand are also subject to 15% WHT:
Difference between the redemption
price and the initial sale price ofbonds issued by the government,
state enterprises, and speciﬁed
institutions.

Gains on the transfer of bonds issued
by the government, state enterprises,
and speciﬁed institutions.

Capital gains received by a Thai company and a foreign company carrying
on business in Thailand from the sale of fund units in a ﬁxed income
mutual fund are exempt from tax. This is subject to the condition that thecost of the investment and expenses relating to the exempt income are
not claimed as tax deductions.

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Dividend income
Dividends received by a company listed on the Stock Exchange ofThailand (SET) from another Thai company are exempt from tax
provided that the shares are held for at least three months before andafter the dividend is received.
Dividends received by a non-listed company from another Thai company
are also exempt from tax provided that the company receiving thedividend holds at least 25% of the total shares with voting rights, without
any direct or indirect cross-shareholding, and has held the shares for atleast three months before and after the dividend is received.
However, if the shares are held for such period but the 25% shareholding
and cross-shareholding conditions are not met, only one-half of thedividend is exempt from tax.
Dividends received from foreign investments are exempt from tax if theThai company receiving the dividends holds at least 25% of the shareswith voting rights of the company paying the dividends for a period of
not less than six months before the date on which the dividend wasreceived and the dividend was derived from net proﬁt in the foreigncountry taxed at a rate of not less than 15%.
If a ‘special law’ in a particular foreign country provides a reduced tax
rate or exemption for the net proﬁt, the limited company receiving thedividends is still eligible for the tax exemption.
The share of proﬁts received by a Thai company or a foreign company
carrying on business in Thailand from an unincorporated joint venturecarrying on business in Thailand is exempt from tax. In addition, certain
proﬁts from mutual funds are exempt from tax (e.g. proﬁt-sharing
received from ﬁxed income mutual funds).
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Stock dividends are taxable to the recipient as ordinary income. Interest
and royalty are taxable as income on an accrual basis.

Foreign income
Companies incorporated in Thailand are taxed on worldwide income.
The foreign income received by a company incorporated in Thailand istaxable on the accrual basis. Double taxation is relieved by way of acredit against the tax chargeable in Thailand.

Net operating losses
Losses may be carried forward to offset against the proﬁts of the following
ﬁve accounting periods. The carry back of losses is not permitted. Achange in control of a loss-making company does not impact its loss
carry forward status.

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Group taxation
Group taxation is not permitted in Thailand.

Transfer pricing
On 21 November 2018, Thailand introduced
speciﬁc transfer pricing provisions into theincome tax law, which apply to accounting
periods that started on or after 1 January
2019.
The transfer pricing rules adopt the arm’s
length principle. Revenue ofﬁcers have thepower to uplift or reduce taxpayers’ revenue
and expenses to the arm’s length price.
Where transfer pricing adjustments resultin a tax shortfall, a secondary adjustment
which arises from imposing tax on aconstructive transaction, either in the formof a deemed dividend or deemed loan,
would also apply.
The legislation also requires mandatory
annual transfer pricing reporting for
taxpayers belonging to a group of companies(‘applicable taxpayers’). Entities with anannual total revenue of THB200m or lessare exempt from the transfer pricing
information reporting requirements.

Two levels of transfer pricing information reporting:1

Partial disclosure – Applicable taxpayers are required to complete a transfer
pricing disclosure form and submit it online to the Revenue Department at
the time of ﬁling the annual tax return.

2

Full disclosure – Applicable taxpayers are also required to prepare fulltransfer pricing documentation to be maintained for ﬁve years from the dateof ﬁling the transfer pricing disclosure form. This includes the local ﬁle andthe master ﬁle for larger entities and is to be submitted to the Revenue
Department within a prescribed time period (normally 60 days) from the dateof the request. A penalty of up to THB200k for each level of transfer pricing
reporting will be imposed in the case where taxpayers fail to comply with thereporting requirements (by way of inaccurate or incomplete disclosure of
information).

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The detailed content requirements of the transfer pricing documentation are
applicable for accounting periods that started on or after 1 January 2021. The newcontent requirements are largely in line with those suggested by the OECD local
ﬁle requirements. However, transfer pricing documentation must be submitted in
the Thai language. It also remains unclear whether Thailand’s transfer pricing
documentation now only comprises the local ﬁle as there is no mention of themaster ﬁle.
Additionally, Thailand also introduced country-by-country reporting (CbCR)
requirements that are applicable for accounting periods starting on or after
1 January 2021. Multinational enterprises (MNE) carrying on business in Thailand
with total consolidated revenues exceeding THB28bn are required to ﬁle the CbCR
in Thailand if they don’t meet the local ﬁling exemption conditions. The Revenue
Department allows a foreign company to designate a Thai entity to be its surrogate
parent entity and ﬁle a CbCR on behalf of the group, with certain conditions to be
met.
The CbCR is required to be ﬁled online within 12 months from the ﬁnancial year-end
if the ultimate parent entity of a Thai MNE is the ﬁling entity and within 60 days
upon request if the ﬁling entity falls under the local ﬁling conditions. Each MNEgroup operating in Thailand and meeting the CbCR threshold must select a
representative entity to ﬁle the CbCR notiﬁcation online with the Revenue
Department. A ﬁne of THB2,000 will be imposed on a taxpayer that fails to ﬁle the
CbCR by the due date.

Thin capitalisation
There are no thin capitalisation rules. However, for certain businesses or as
part of the conditions for granting tax incentives, a certain debt-to-equity
ratio may be required.

Controlled foreign companies (CFCs)
There are no tax provisions in respect of CFCs.

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Tax credits and incentives
BOI tax incentives
Under the Investment Promotion Act of 1977 (including
its amendment no. 4 of 2017) and the Competitive
Enhancement Act of 2017, the BOI is authorised to
grant incentives and privileges to qualiﬁed investments.
An investor entitled to investment incentives from the
BOI under the Investment Promotion Act must be alimited company, foundation or cooperative organised
under Thai law. However, an investor under theCompetitive Enhancement Act can only be in the formof a limited company.
The present criteria for investment promotion became effective on 1 January
2015 while the status of existing promotional privileges already granted
didn’t change.
To relax the foreign shareholding limitation and to facilitate investors inmaking investments, the following criteria are currently used by the BOI:
For a project in agriculture, animal husbandry, ﬁshery, mineral exploration andmining and service businesses under Schedule 1 of the Foreign Business Act
of 1999, Thai nationals must hold not less than 51% of the registered capital.
For manufacturing projects, foreign investors may hold a majority or all of theshares in promoted projects.
The BOI may specify the foreign investor shareholding in promoted projects
when it is deemed appropriate.

With effect from 25 January 2017, the amended Investment Promotion Act
offers a maximum CIT exemption period of 13 years, and from 14 February
2017 the Competitive Enhancement Act extended the exemption period
to a maximum of 15 years. In addition, it provides for a competitiveenhancement fund of THB10bn which is intended to lure high-value
investors in industries using advanced technologies, geared towards
innovation and research and development. However, obtaining privileges
under both Acts is not feasible as the investor will only be allowed to use
the privileges under one of the Acts.
The BOI provides tax and non-tax incentives under both Acts as well as
various guarantees and protection measures which vary with the natureand importance of the activities, project locations, and other criteria.
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Tax incentives that may be granted toinvestors:• Exemption from or reduction of import duties on imported
machinery.
• Exemption from import duties on raw and essential materials
imported for manufacturing for export.
• Reduction of import duties on raw and essential materials by
up to 90% for use in manufacturing for domestic sale.
• Exemption from import duties on items used for R&D.
• Exemption from CIT with or without a cap equal to or morethan the amount of the investment, excluding the cost ofland and working capital, for up to 15 years, depending on
the applicable law, the promoted activity and the location.
• 50% reduction in the CIT rate for a maximum of ﬁve years
from the date on which the tax holiday expires.
• Exclusion of dividends received from promoted enterprises
from taxable income during the period of CIT exemption andwithin six months from the date on which the tax exemption
period expires.
• Double deduction of the cost of transportation, electricity, andwater supply for ten years from the date on which revenue
was ﬁrst derived from the promoted activity.
• Deduction of 25% of the project’s infrastructure installationor construction costs in addition to normal depreciation. The
deduction can be made in one or several years within ten
years from the date on which revenue was ﬁrst derived fromthe promoted activity.

Additional incentives based on the value of a project(merit-based incentives) are also available, asdetailed below, in order to motivate investors applying
under the Investment Promotion Act to invest in or
spend on activities that will beneﬁt the country or theindustry as a whole.

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Tax incentives
be granted to
Merit thatfor may
decentralisation
investors:

The BOI grants an additional decentralisation merit for businesses that arelocated in 20 targeted provinces, which includes the following incentives:
A further three years’ tax exemption period from the standard incentives, but
not exceeding 13 years in total. With the exception of the targeted core
activities, those activities that have eight years’ tax incentives will receive a
50% reduction in the CIT rate on net proﬁt derived from the promoted
activity for ﬁve years after the termination of the normal income tax holiday,
or from the date of earning income if no tax holiday is granted.
A double deduction of the cost of transportation, electricity and water supply
for ten years from the date on which revenue was ﬁrst derived from thepromoted activity.
A 25% deduction of the project’s infrastructure installation or construction
costs in addition to normal depreciation. The deduction can be made fromthe net proﬁt of one or several years within ten years from the date on whichrevenue was ﬁrst derived from the promoted activity.

Merit for research and development
The BOI will grant an additional investment cap of up to 300% of thepermitted expenses incurred for internal R&D, the provision of advanced
training to employees, or the development of local suppliers and a further
tax exemption period of up to three years (not exceeding 13 years in total).

Merit for industrial area development
The BOI will grant one additional year of tax exemption for activities thathave tax incentives and are located within an industrial estate or promoted
industrial zone. However, the total period of tax exemption will not exceed
eight years, except for activities under technology and innovation
development, which will be entitled to a maximum beneﬁt of 11 years CIT
exemption without any cap.

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Tax incentives
that maybetechnologies
granted toTargetedcore
and enabling
investors:
services
The BOI has also designated activities as targeted core technologies
which, together with the enabling service of research and development,
are entitled to a maximum beneﬁt of 13 years of CIT exemption without
any cap. The targeted core technologies are as follows:

Biotechnology

Nanotechnology

Advanced material
technology

Digital technology

The enabling services of research and development will support thetargeted core technologies in the following industries:

Bio andmedicalAdvancedmanufacturing

Basic andsupporting

Creative anddigitalOther incentives, guarantees and protection
measures
Apart from the tax incentives, other incentives granted to a promoted
enterprise include permission to bring in foreigners to engage in investment
feasibility studies, to bring in foreign technicians and experts to work on
promoted projects, to own land to undertake the promoted activities andto remit foreign currency abroad.
The BOI provides guarantees against nationalisation, competition fromnew state enterprises, state monopolisation of the sale of products similar
to those produced by the promoted project, price controls and tax-exempt
imports by government agencies or state enterprises.
Protection measures include the imposition of a surcharge on imports,
import bans on competing products and the authority of the Chairman of
the BOI to order any action or tax relief measures for the beneﬁt ofpromoted projects.

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Special economic
development zones
Special economic development zones(SEZ) are border areas, whether insideor outside of industrial estates, to create
economic connectivity with neighbouring
countries. The zones include certain areas(sub-districts) in the provinces of Trat,
Tak, Mukdahan, Songkhla, Sa Kaeo,
Nong Khai, Kanchanaburi, Chiang Rai,
Nakhon Phanom and Narathiwat.

Chiang Rai

Nong Khai
NakhonPhanomTak

MukdahanKanchanaburi

The BOI has granted tax incentives forinvestment in eligible target and generalactivities in the SEZ. To be eligible forthe tax privileges, a number of generaland speciﬁc conditions need to be
fulﬁlled, including the use of modern
production processes and newmachinery, the necessary amount ofpaid-up share capital, adequate
environment protection systems,
a debt-to-equity ratio not exceeding 3:1
and the required area to operate thebusiness.

Sa Kaeo
Trat

Songkhla
Narathiwat

Tax incentives available for eligible target activities:• Exemption from CIT for a maximum period of eight years, with or without a cap equal tothe cost of the investment (excluding cost of land and working capital).
• 50% reduction in the CIT rate for ﬁve years from the date on which the tax holiday
expires.
• Double deduction of the cost of transportation, electricity and water supply for a periodof ten years from the date on which revenue from the BOI business was ﬁrst generated.
• A 25% deduction of the investment cost of the installation or construction of facilities in
addition to normal depreciation.
• Exemption from import duty on machinery.
• Exemption from import duty on raw materials and essential goods used in the productionof goods for export for a period of ﬁve years.

Permission will be granted to employ foreign unskilled workers in the promoted
project according to the conditions prescribed by the BOI.
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Tax incentives available for eligible general activities:

CIT exemption for an
additional three years, but
not exceeding eight years
in total.

50% reduction in the CIT
rate for ﬁve years from thedate on which the tax
holiday expires for certain
speciﬁed activities which
are entitled to eight years’tax exemption.

Other incentives are thesame as those for theabove eligible target
activities.

Applications to obtain investment promotion in the SEZ must be submitted by 30
December 2022.

IEAT free zone
Under the Industrial Estate Authority of Thailand (IEAT) law, the free zone
is designated for the operation of industrial and commercial activities orother related businesses, for the purpose of the economy, national
security, public wellbeing, environmental management, or other necessities
as prescribed by the IEAT Board, whereby goods taken into the area will
be entitled to additional tax and duty rights and privileges as well as
special fees as provided in the law.

Additional privileges granted to industrial operators in an
IEAT free zone:• Exemption from import duties, VAT and excise tax on machinery, equipment,
tools, and supplies (including components) which are essential for the
production of goods or for commercial purposes and on materials to be usedin the construction, assembly or installation of factories or buildings in the IEAT
free zone. Consumer products or vehicles are not exempt.
• Exemption from import duties, VAT and excise tax on raw materials imported
and taken into an IEAT free zone for use in the production of goods or forcommercial purposes. Exempt imported materials taken into an IEAT freezone for use in production include items from another IEAT free zone,
promoted persons under the BOI for export, bonded warehouse, items
imported under bank guarantee for re-export of ﬁnished goods and items
exempt under other laws.
• Importation of goods into an IEAT free zone for producing, mixing, assembling,
packing, or processing of the goods for export out of Thailand are not subject
to the law in relation to the control of importation or exportation, the control
of standards or quality, afﬁxing of a mark or any signs to those goods otherthan those required under the Customs law in accordance with the rules
prescribed by the Board of the IEAT.
• Goods manufactured in an IEAT free zone and sold in Thailand will be deemed
as imported goods and subject to import duties and VAT. Sales between
operators located in the IEAT free zones could be subject to VAT at thenormal rate or at a zero rate.
• Goods manufactured in an IEAT free zone which qualify under the rules oforigin and manufacturing criteria may be entitled to preferential duty rates on
their removal to the Thai domestic market.
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Customs free zone
To support and promote the country’s exports, a customs free zone (CFZ)
is an area designated for industrial or commercial operations, or otherbusinesses that are beneﬁcial to Thailand’s economy. Goods imported
into or manufactured in this zone will be exempted from import duty, VAT
and excise tax.
To qualify as a CFZ, an application for its establishment must be submitted
for the approval of the Director-General of the Customs Department. A
company permitted to establish or operate in the CFZ must conclude aguarantee agreement with the Customs Department, conform strictly to
all customs regulations and pay an annual fee as ﬁxed by the law.

Rights and privileges granted to an operator in a CFZ:
Exemption from payment of import duties, VAT and excise tax on theacquisition (including the transfer from another CFZ) of machinery, equipment,
tools and supplies (including components) which are essential for use inindustrial and commercial operations or any other businesses that are
beneﬁcial to the economy of the country.
Exemption from payment of import duties, VAT and excise tax on raw
materials imported and taken into a CFZ for use in the production of goods
or for commercial purposes. Exempt imported materials taken into a CFZ
for use in production include items from another CFZ, promoted persons
under the BOI for export, bonded warehouse, items imported under bankguarantee for re-export of ﬁnished goods and items exempt under other laws.
Importation of goods into a CFZ for producing, mixing, assembling, packing
or processing of the goods for export out of Thailand will be exempted fromthe law in the part relating to the control of standards or quality, afﬁxing ofa mark or any signs according to the rules prescribed by the Director-General.
Goods manufactured in a CFZ and sold in Thailand will be deemed asimported products and subject to duties and VAT. Sales between operators
located in the CFZ could be subject to VAT at the normal rate or a zero rate.
Goods manufactured in a CFZ which qualify under the rules of origin andmanufacturing criteria may be entitled to preferential duty rates on theirremoval to the Thai domestic market.

The storage period for goods in free zones (both IEAT and Customs) islimited to two years. However, the two-year limit can be extended foranother year if the CFZ/IEAT free zone company obtains approval from
Customs or IEAT (depending on the type of free zone). The approval needs
to be obtained within 30 days before the expiry date of the two-year
limitation. Goods that have been stored but have not obtained approval
for the extension within 30 days from the expiry date will be subject toimport duty and taxes.
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International business centre
An international business centre (IBC) regime has been launched toreplace the previous regional operating headquarters (ROH), international
headquarters (IHQ) and international trade centre (ITC) regimes, whichhave been terminated.
The criteria for the establishment and operation of an IBC are as follows:
A Thai company incorporated for the purpose of providing management,
technical, support or treasury management services to its associatedenterprises or for undertaking international trade business.
Paid-up capital on the last day of each accounting period of at least
THB10m.

Provision of management, technical, support or treasury management
services to its associated enterprises.

At least ten knowledgeable and skilled personnel working full time for
the IBC or at least ﬁve if the IBC acts only as a treasury centre.

Expenses for the operation of the IBC paid to recipients in Thailand mustnot be less than THB60m in each accounting period.

Management, technical and support services comprise:

General management,
business planning,and business coordination

Procurement of
raw materials and parts

Research anddevelopment of productsTechnical support

Marketing andsales promotion

Personnel management
and training

Financial advice

Economic and investment
analysis and research

Credit control
and management

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Treasury management services comprise:
Treasury management of a treasury centre as permitted under the exchange
control law
Borrowing and lending in Thai baht of a treasury centre as permitted under theexchange control law

International trading business means the international business of buying andselling goods, which may include the provision of services related to the goods
purchased and sold. These services include:

Procurement of goods

Storage of goods while
awaiting delivery

Packing and packaging

Transportation of goods

Insurance of goods

Technical advice andservices and producttraining

Income of the IBC means:
Income from the provision of management, technical, support services, ortreasury management to its associated enterprises.
Royalties from associated enterprises arising from a result of research anddevelopment carried out in Thailand by the IBC or other entities hired by the
IBC, according to the rules, procedures, and conditions prescribed by the
Director-General of the Revenue Department.

The following tax beneﬁts are available for 15 accounting periods:
Reduced rates of CIT on qualifying income:8%

if the IBC has incurred
expenditure of at least
THB60m paid to recipientsin Thailand during theaccounting period.

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5%

if the IBC has incurred
expenditure of at least
THB300m paid torecipients in Thailand
during the accounting
period.

3%

if the IBC has incurred
expenditure of at least
THB600m paid torecipients in Thailand
during the accounting
period.
40

Exemption from tax on dividends derived by the IBC from its afﬁliates.
Exemption from withholding tax on dividends paid by the IBC to a non-resident
company out of proﬁts derived from qualiﬁed service income subject to the
reduced rate of tax.
Exemption from withholding tax on interest paid by a treasury centre on
borrowed funds which are re-lent to afﬁliates.

Exemption from speciﬁc business tax on income received by a treasury centre.

Personal income tax rate of 15% for expatriate full time employees of the IBC
and working for the IBC. If the company undertakes IBC as well as otherbusinesses, the revenue derived from the IBC must not be less than 70% of
the company’s total revenue.

In comparison with the previous ROH/IHQ regimes, the IBC regime doesn’t apply
different tax rates to offshore and onshore income. As a consequence, there is nolonger any requirement for services to be provided to a minimum number ofoffshore afﬁliates. There is also no limit to the amount of onshore income which
qualiﬁes for the reduced tax rates. The expenditure required to qualify for the
reduced tax rates has been signiﬁcantly increased.
However, in the case where an existing ROH/IHQ has converted to be an IBC, it
can enjoy the reduced tax rate of 8% provided that it meets the original minimum
expenditure requirement of THB15m.
If an IBC doesn’t meet the rules and conditions prescribed or does not otherwise
qualify as an IBC in any accounting period, the beneﬁts will be revoked on a
year-by-year basis. If the company doesn’t meet the conditions for more than one
accounting period or has none of characteristics for operating as an IBC, the tax
beneﬁts will be terminated with effect from the ﬁrst accounting period.
The taxable proﬁt and loss of an IBC must be computed separately between the
IBC and non-IBC businesses and between (i) headquarters and treasury
management services, and (ii) royalties. Common expenses are to be allocatedbased on the proportion of revenue of the IBC and non-IBC businesses.

Tax losses must be maintained separately, as follows:

Headquarters and treasury
management services

Royalties

Non-IBC businessTax returns must be ﬁled separately for each of the above services.
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About PwC

The New Equation
The world has forever changed after the pandemic. Building
trust and delivering sustained outcomes has never been
more important in a world faced with disruptions such astechnological revolution, climate change and social tensions.
Our global strategy, The New Equation, is our commitment
to co-create solutions to help our clients overcome newchallenges in this rapidly changing world by bringing
together unique combinations of people and technology
to meet complex needs. It is our purpose, which empowers
our people to deliver real change for clients, stakeholders
and society.
Not only do we strive to deliver quality assurance, advisory
and tax services but we are also continuing to attract
diverse talent and upskilling our people to meet the needsof today and tomorrow.

PwC l Doing Business in Thailand 2022

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PwC operations inThailandPwC has had a presence in Thailand for many
years and this year is our 63rd anniversary
in the market. We work closely with a diverse
range of clients, including multinational
companies, public sector entities, businesses
with high growth potential and prospective
entrepreneurs.
True to our commitment to The New Equation
and as part of a community of solvers, wehelp our clients cope with the businessdisruptions of today and tomorrow while also
highlighting the importance of sustainable
practices. This means bringing in the bestof our people and combining them with
innovative technologies to ensure ourclients can build trust and deliver sustained
outcomes.
We believe that sound governance andtransparency form the bedrock of leadership,
and we are committed to serving withintegrity and good sense. We have more than
1,800 people ready to deliver Assurance,
Tax and Legal, Deals and Consulting services.

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Delivering sustained outcomes whichmake a difference
Assurance services
Trust is essential for business ethics. It matters to clients,
stakeholders and investors alike. In an age where the paceof business is accelerating and regulations are shifting
fast, trust is perhaps more crucial than ever before. Our
Assurance service aims to deliver a clear path and ensure
your business improves its transparency in digitalassurance, ﬁnancial reports and Environmental, Social andGovernance (ESG) reporting.

Tax and Legal services
Achieving your tax strategy in today’s business landscaperequires expertise and foresight to meet the many
challenges. Our Tax and Legal service is your trusted
advisor in building strong relationships with regulators andbetter managing tax pitfalls. By combining the best of
our people, global network and technology, we helporganisations stay in compliance and give them time tofocus on their future.

Deals services
Driving value through business deals, mergers, acquisitions,disposals and restructuring forms the core of our services.
Our team understands that all deals are unique, so wedeliver the expertise you need at every stage of the deal
to make sure you don’t leave value on the table.

Consulting services
As part of the PwC South East Asia Consulting joint venture,
our Consulting business in Thailand brings the best
regional and local experts to help our clients succeed. We
combine technology and industry knowledge to guide
your business in digital and cloud transformation, risks
and strategy.

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Contacts
Assurance
Amornrat Pearmpoonvatanasuk
Assurance Lead Partner
E: amornrat.pearmpoonvatanasuk@pwc.com
Tax and Legal
Somboon Weerawutiwong
Lead Partner, Tax and Legal Services
E: somboon.weerawutiwong@pwc.com
Deals
Chantanuch Chotikapanich
Deals Lead Partner
E: chantanuch.chotikapanich@pwc.com
Consulting
Vilaiporn Taweelappontong
Consulting Lead Partner and Financial Services Leader
E: vilaiporn.taweelappontong@pwc.com

Our Ofﬁce
PwC Thailand
15th Floor Bangkok City Tower,
179/74-80 South Sathorn Road,
Bangkok 10120
T: +66 (0) 2844 1000

PwC l Doing Business in Thailand 202246

www.pwc.com/th© 2022 PwC. All rights reserved. PwC refers to the Thailand member ﬁrm, and may sometimes refer tothe PwC network. Each member ﬁrm is a separate legal entity. Please see www.pwc.com/structure forfurther details.