The Thai Revenue Department (RD) issued Revenue Ruling No. GorKor 0706 (GorMor.08)/577 on 9 May 2006, in which the RD adopted the position of applying the "beneficial owner" concept in order to determine the rate of withholding tax applicable to interest paid to a company residing in the United States.
In general, when a Thai company pays interest on a loan or debentures to a f…