Regional headquarters (IBC) in Thailand.
Thailand's International Business Center (IBC) regime — successor to the older Regional Operating HQ — gives reduced corporate-tax rates and personal-tax incentives for senior expatriates managing affiliates from a Thai base.
What is the IBC regime?
The International Business Center (IBC) is Thailand's regime for companies that run regional management, technical, support, and treasury functions for their group from a Thai base.
It is the current scheme — and the one any new regional headquarters should use. The older Regional Operating Headquarters (ROH), International Headquarters (IHQ) and International Trading Center (ITC) regimes were consolidated into the IBC in 2018–2019, and their incentives have since lapsed. Administered jointly by the Revenue Department and the BOI, the IBC pairs a reduced corporate-tax rate and personal-tax relief for senior expatriates with genuine substance requirements, and its benefits run for up to 15 accounting periods.
What the IBC gives you.
Reduced tax on qualifying income, relief on cross-border flows, and a concessionary rate for the people who run it.
Reduced corporate tax
8%, 5% or 3% on qualifying income — versus the standard 20% — set by how much the IBC spends in Thailand each year: at least THB 60 million, THB 300 million, or THB 600 million respectively.
15% for senior expatriates
Qualifying expatriate staff can elect a flat 15% personal income tax on IBC employment income, subject to residence, salary and position thresholds.
Cross-border tax relief
Withholding-tax exemption on dividends paid from the IBC to non-resident companies and on interest on funds re-lent to affiliates, plus specific business tax relief on qualifying treasury-centre income.
What you must commit to keep it.
The IBC's tax position is earned, not granted on paper. Two things have to be true and stay true: real substance in Thailand, and genuinely qualifying services to your group.
Requirements you maintain
- At least THB 10 million paid-up capital at the end of each accounting period
- At least 10 skilled full-time employees — or 5 where the IBC only runs treasury-centre activities
- Minimum local operating expenditure matched to the rate tier (THB 60m / 300m / 600m)
- Conditions met in every accounting period, with benefits available for up to 15 periods
Qualifying services
- Management and business-administration services
- Technical and support services
- Treasury-centre functions for the group
- Provided to associated enterprises in Thailand or abroad
The global minimum tax (Pillar Two).
For large groups, the headline 3–8% rate is no longer the whole story.
Thailand adopted the OECD Pillar Two global minimum tax for accounting periods beginning on or after 1 January 2025. Multinational groups with consolidated revenue above EUR 750 million face a 15% top-up tax that can offset the IBC's reduced rates, so the net benefit for an in-scope group may be smaller than the headline suggests. The BOI and Revenue Department have introduced relief options — including a qualified refundable tax credit — for affected investors. We model the position with and without the IBC, and against the top-up tax, before recommending a structure.
How to set up an IBC, step by step.
From testing whether it beats your current structure to maintaining the status year on year.
Fit & benefit assessment
We model the tax position with and without an IBC, factoring in the minimum-expenditure, capital and staffing thresholds — and the Pillar Two top-up where it applies.
Structure design
We map which entity provides which services to which affiliates, and agree the transfer-pricing approach between the Thai IBC and the group.
Applications
IBC status is applied for with the Revenue Department and, where relevant, BOI promotion for additional benefits.
Setup
Entity registration, accounting setup, and personal-tax registration for qualifying expatriate staff.
Annual maintenance
Reporting to the BOI and the Revenue Department, and evidencing the capital, employment and expenditure conditions in each period.
How we help you set up an IBC.
The International Business Center regime, administered jointly by the Revenue Department and BOI, lets a Thai entity provide management, technical, financial, and treasury services to its affiliates at a reduced corporate-tax rate (8%, 5%, or 3% depending on operating expenditure in Thailand) and at 15% personal income tax for qualifying senior expatriate staff.
It is not a generic incentive. The Thai entity must provide qualifying services to at least one foreign affiliate; it must employ a minimum number of Thai staff with relevant skills; and it must spend a minimum amount of operating expenditure in Thailand per year. Below those thresholds, the regime doesn't apply.
We assess fit, set up the IBC entity, register with the Revenue Department and BOI, and stay on for the annual reporting that maintains the status.
What we do
- IBC eligibility and benefit assessment
- Structure design — what entity provides what services to which affiliates
- BOI and Revenue Department applications for IBC status
- Transfer-pricing documentation between the Thai IBC and foreign affiliates
- Personal-tax registration for qualifying senior staff
- Annual IBC compliance reporting
What you get
- Pre-investment assessment — we tell you whether IBC actually beats your current structure
- Coordinated with corporate-tax and transfer-pricing planning
- Annual maintenance handled per filing
How we work
Fit and benefit assessment
We model the tax position with and without IBC, accounting for the minimum-expenditure and Thai-staff requirements.
Structure design
Service flows between the Thai IBC and foreign affiliates documented; transfer-pricing approach agreed.
Applications
IBC status applied at the Revenue Department and, where relevant, BOI promotion for additional benefits.
Setup
Entity registrations, accounting setup, personal-tax registration for expatriate senior staff.
Annual maintenance
Reporting to BOI and the Revenue Department to maintain IBC status.
Speak with our team
Send a message — typical response within one hour during office hours.
WhatsApp +66 95 332 2447 Send an Enquiry Call +66 2 026 0600Frequently asked
What's the difference between the old ROH and the current IBC?
The Regional Operating HQ (ROH) and International HQ (IHQ) regimes were consolidated into the IBC regime. The IBC is the current incentive structure.
How low can the corporate tax rate go?
8% if operating expenditure in Thailand is at least THB 60 million per year; 5% at THB 300 million; 3% at THB 600 million.
Who qualifies as 'senior expatriate' for the 15% personal-tax rate?
Specific position and salary thresholds apply. We document these as part of the application.
How many Thai staff are required?
Minimum 10 Thai employees with relevant skills, plus a minimum operating expenditure threshold. Both must be maintained annually.
Reviewed by the Khonsu Legal team · 1 July 2026
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