Thailand — Orbitax Country Chapters

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Thailand — Orbitax Country Chapters

Table of Contents

1. FORMS OF DOING BUSINESS

1.1. Main Forms of Doing Business with a Legal Presence

1.1.1. Main Forms of Doing Business

2.1. Main Formation Requirements

3. CORPORATE RESIDENCE

3.1. Corporate Tax Residence

4. PERMANENT ESTABLISHMENTS

4.1. Domestic PE of a Foreign Entity

4.2. PE-Risk Grid for Foreign Entities Involved in Business Activities

4.3. Branch Profit (Deemed Remittance) Tax

5.1. Tax Base for Resident Entities

5.2. Treatment of Foreign Profits / Losses

5.3. Tax Consolidation / Group Treatment

5.4. Tax Base for Non-Resident Entities

5.5. Source Rules with Respect to Income Derived by Non-Residents

5.6. Qualification of Specific Income Categories for Tax Purposes

6. DETERMINATION OF TAXABLE INCOME

6.1. Main Differences between Commercial and Tax Accounting

6.2. Depreciation and Amortization

6.3. Deduction of Cross-Border Payments and Non-Deductible Expenses

6.4. Taxation of Foreign-Source Income

7.1. General Rules

8.1.1. Other Taxes

8.2. Non-Residents

8.2.1. Corporate/Profit Taxes

8.2.2. Withholding Taxes

9. ELIMINATION OF DOUBLE TAXATION

9.1. Unilateral and Treaty Based Methods Available for the Elimination or Mitigation of Double Taxation

10. INCENTIVES AND SPECIAL REGIMES

10.1. Specific Incentives

11. VAT ON INTERNATIONAL TRANSACTIONS

11.1. VAT on the Supply of Goods by Non-Residents

11.2. VAT on the Supply of Services by Non-Residents

11.3. Refund of VAT to Non-Residents

12. BASE PROTECTION AND ANTI-AVOIDANCE MEASURES

12.1. GAAR and General Anti-Avoidance Measures

12.2. Thin-capitalization and other Restrictions to Interest Deduction

12.2.1. Main Rules

12.3. CFC and Similar Regimes

12.3.1. Main Rules

12.4. Transfer Pricing

12.4.1. Main Rules

12.4.2. Specific TP Issues

12.4.3. Documentation Requirements

12.4.4. APAs and Dispute Resolution Mechanisms

12.5. Other Anti-Avoidance Rules

13. TAX MANAGEMENT AND COMPLIANCE

13.1. Books and Records

13.2. Type of Assessment

13.3. Calendar of Important Compliance Events

13.4. Tax Audits

13.4.1. Audit Process

13.4.2. Statute of Limitations

13.5. Interest and Penalties

13.6. Interest Compensation for Overpayment of Tax

13.7. Appeal Procedures

3.1. Corporate Tax Residence

Thailand follows the incorporation theory. A company incorporated under Thai law is deemed to ...