The standard corporate tax rate is 20%.

Small and Medium-sized companies are eligible for a reduced tax rate as follows:

Income up to THB 300,000 is exempt from tax; and
Income above THB 300,000 and up to THB 3 million is subject to a reduced tax rate of 15%.

In order to be eligible for the reduced tax rate and exemption, the company’s paid-up capital must be THB 5 million or less, and annual turnover may not exceed THB 30 million in any accounting period.

International companies engaged in oil exploration and production activities are taxed under a concession, a production sharing contract, or a service contract in Thailand. Petroleum companies under a concession are taxed at the rate of 50% of their annual net profit from petroleum operations. Petroleum companies under a production sharing contract are taxed at the rate of 20% of annual net profits.

Effective 13 November 2019, mutual funds are subject to tax at the rate of 15% on their gross income received after 20 August 2019. The tax is deducted by way of withholding tax by the payer of the income. Such tax may be considered as a final tax by the mutual funds for the purpose of tax returns.

Capital Gains

Capital gains are generally treated as ordinary business income and are charged to tax at standard corporate tax rates.

Dividends

Dividends are generally treated as ordinary business income and are charged to tax at standard corporate tax rates. In general, 50% of the dividends received by resident companies from other resident companies are exempt from tax. Dividends received from other resident companies and those received from non-resident companies may be fully exempt, provided specified conditions are met (see Sec. 5.1.).

Pillar Two Global Minimum Tax

On 20 December 2021, the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS) released model rules called Global Anti-Base Erosion (GloBE). These rules basically provide for a co-ordinated system of taxation that is intended to reform international tax rules and ensure that large multinational enterprise (MNE) groups pay a minimum level of tax on the income arising in each of the jurisdictions where they operate.

Essentially, the Pillar Two rules provide for the implementation of an Income Inclusion Rule (IIR) and an Undertaxed Profits Rule (UTPR) with respect to in-scope MNEs, being those with annual consolidated revenues of EUR 750 million or more in at least two of the four fiscal years immediately preceding the tested fiscal year. Under the Pillar Two rules, taxpayers in scope of the rules are required to calculate their effective tax rate for each jurisdiction where they operate and pay Top-up tax for the difference between their effective tax rate per jurisdiction and the 15% minimum rate. Any resulting Top-up tax is generally charged in the jurisdiction of the ultimate parent of the MNE. Further, the Pillar Two rules also allow jurisdictions to opt for the adoption of a Qualified Domestic Minimum Top-up Tax (QDMTT) based on the GloBE mechanics, thus eliminating the potential application by other jurisdictions of top-up taxes to their resident entities.

On 26 December 2024, Thailand published the Emergency Decree for the introduction of global minimum tax (GMT) rules in line with OECD’s Pillar Two Model Rules, including an IIR, a UTPR and a Domestic Minimum Top-up Tax (DMTT, intended to be a QDMTT) for MNEs meeting a consolidated annual revenue threshold of EUR 750 million in at least two out of the four preceding fiscal years, effective 1 January 2025.

Excluded Entities

The following entities are excluded from the scope of application of the GMT:

Government entities, international organizations, non-profit organizations, and pension funds; and
Investment funds and real estate investment vehicles but only when they are the Ultimate Parent Entity (UPE) of an MNE Group.

The Decree does not provide any details on GloBE income adjustments, adjusted covered taxes or relevant safe harbors and these are expected to be detailed in Ministerial Regulations.

Notification

The in-scope MNE must submit a notification within 15 months from the end of the reporting period (18 months in the transitional year i.e., by 30 June 2027 for the financial year ending 31 December 2025). The notification will include information on the UPE, the country where it is located and the designated constituent entity responsible for filing the GloBE Information Return. The constituent entities are exempted from filing the notification if a designated filing entity is appointed to file the notification on their behalf.

Filing of Top-Up Tax Returns and Payment

A GloBE information return must be furnished by the UPE or designated filing entity within 15 months from the last day of the relevant financial year (18 months for the first year of application, i.e., by 30 June 2027 for the financial year ending 31 December 2025), and must contain the details of the top-up tax calculation. The obligation to file the information return in Thailand is waived if a constituent entity within the MNE group has filed the information return in another jurisdiction, provided a competent authority agreement exists between Thailand and that jurisdiction for the automatic exchange of information returns; and
A top-up tax return must be filed and the top-up tax must be paid within 15 months from the last day of the relevant financial year (18 months for the first year of application, i.e., by 30 June 2027 for the financial year ending 31 December 2025). The payment of the Top-up tax is to be made in Thai currency irrespective of the currency used for accounting purposes.

Reduced Tax Rate Regime to Mitigate the Impact of Pillar Two

On 7 June 2023, to mitigate the impact of Pillar Two, the Thai BOI approved changes to the BOI tax exemptions regime (see Sec. 10.1.), whereby companies benefiting from or eligible for a corporate tax exemption may instead elect to be taxed at an alternative reduced tax rate of 10% (being half the current standard corporate tax rate). The reduced tax rate alternative is open to:

Companies that are members of groups with consolidated revenue of THB 28 billion or more; or
Companies that are subject to Country-by-Country reporting requirements for the previous accounting period.

Qualifying companies currently enjoying a tax exemption are allowed to convert to the reduced tax rate regime for a period of up to twice the remaining years of exemption, up to a maximum of 10 years. New companies have the option to apply the tax exemption regime or the reduced tax rate regime. If the tax exemption regime is applied, the company can subsequently convert to the reduced tax rate regime. The period for the reduced tax rate regime for new companies is twice the period for the tax exemption regime, which varies depending on the activity, up to a maximum of 10 years.

Withholding Tax

The rates of withholding tax for common payments made to residents are as follows:

Nature of Payment	Withholding Tax Rate
Dividends	10%
Interest (see Note below)	1%
Royalties	3%
Technical Services/ Professional Income	3%
Rent	5%

Note: The 1% withholding tax rate applies to interest paid to resident companies other than banks or finance companies, except for interest arising from bonds or debentures.

COVID-19 Emergency Measures

As a part of a stimulus package to counter the impacts of the COVID-19 pandemic, a reduced domestic withholding tax rate of 1% applies for the period from 1 January 2023 until 31 December 2025, provided the payments are received through the e-withholding tax system (see Sec. 10.1.). The reduced rate of withholding applies to the following payments:

Goodwill, copyright, and other similar rights;
Property rentals except for boat rentals;
Professional services;
Income derived from work contracts; and
Prizes received from competitions, lucky draws, or other similar events.

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