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Thailand: Corporate tax incentives repealed, effective 1 June 2019

Thailand: Corporate tax incentives repealed

The Thai Cabinet in late March 2019 approved three Royal Decrees (as proposed by the Ministry of Finance) cancelling tax incentives previously granted by the Thai Revenue Department under the:


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  • Regional operating headquarters (2010) regime
  • International headquarters regime (including Treasury Centres)
  • International trade center regime

The incentives under these regimes will no longer be available effective 1 June 2019 as corporate income tax incentives, and effective 1 January 2020 as individual income tax incentives. In effect, the previously announced grandfathering of tax incentives under these three regimes will not be allowed.

Thus, assuming that the Royal Decrees implementing these changes are finalized and issued, the following benefits will no longer be available under the three incentive regimes:

  • The corporate income tax rate reduction and exemption on income from provision of services to affiliated companies, as well as interest, royalties and dividends received from affiliated companies (cancelled from 1 June 2019)
  • The exemption from corporate income tax on gains derived from disposal of shares in affiliated companies (cancelled from 1 June 2019)
  • The corporate income tax rate reduction and exemption on income from trading activities and provision of services relating to international trade (cancelled from 1 June 2019)
  • The individual income tax rate reduction applicable to foreigners working under one of the three incentive regimes (cancelled from 1 January 2020)
  • The withholding tax exemption on dividends paid to foreign shareholders (cancelled from 1 June 2019, except for dividends paid out of profits derived before 1 June 2019 provided that the dividends are paid by 31 December 2020)
  • The withholding tax exemption on interest paid by a Treasury Centre to a foreign recipient (the timing of cancellation requires clarification)

All current tax benefits under the regional operating headquarters (2002) regime will also be cancelled; however, there is some uncertainty about the timing.

Read a March 2019 report prepared by the KPMG member firm in Thailand

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