Tax advisory and planning in Thailand.
Structuring decisions, transfer pricing, withholding tax positions, double-tax treaty applications, BOI tax-benefit optimisation, Revenue Department engagement. The work that sits above the monthly compliance.
What is tax advisory & planning in Thailand?
Tax advisory and planning is the work of arranging a company's affairs so that they stay both compliant and efficient across the taxes that touch a Thai business — corporate income tax, VAT, withholding tax, personal income tax, and the cross-border questions that sit between them. Done well, it turns tax from an annual reckoning into a position you can defend and rely on.
It also means keeping pace with a landscape that no longer stands still. The global minimum tax, sharper transfer-pricing rules, and the taxation of foreign income remitted to Thailand have all reshaped the ground in recent years — and a structure that was sound two years ago may now leave value on the table or carry risk that was not there before.
The questions we are asked most.
Six areas account for the bulk of the advisory work — the points where exposure tends to build and where the right position is worth securing in writing.
Permanent-establishment & foreign-company exposure
Whether an overseas parent or a stream of cross-border activity creates a taxable presence in Thailand — and how to structure around it before it does.
Tax health checks & compliance reviews
A structured look back over filings and positions to surface gaps before the Revenue Department does, and to confirm the company is paying neither too much nor too little.
Cross-border transactions, withholding tax & treaties
Characterising payments correctly, applying the right withholding rate, and claiming the relief available under Thailand's double-tax treaty network.
Transfer pricing
Pricing intra-group transactions on arm's-length terms, preparing the documentation, and meeting the annual disclosure obligation.
Rulings, refunds & tax-residency certificates
Securing advance certainty from the Revenue Department, recovering overpaid tax, and obtaining the residency certificates that unlock treaty benefits.
Personal & expatriate tax
Planning for founders, directors, and senior staff — residency, remittances, and the interaction between Thai and home-country liabilities.
The numbers that frame the planning.
Good advice starts from the headline rates — then looks ahead to the changes that are already reshaping how those rates apply.
The headline rates
- Corporate income tax is charged at 20%.
- SMEs — paid-up capital up to THB 5 million and revenue up to THB 30 million — pay nothing on the first THB 300,000 of net profit, 15% on the next band, and 20% above it.
- VAT is levied at 7%, with the reduced rate extended to 30 September 2026.
- Personal income tax runs on a progressive scale from 0% to 35%.
- Withholding tax applies at 10% on dividends and 15% on interest and royalties — often reduced under Thailand's 60-plus double-tax treaties.
On the radar (2025–2026)
- The OECD Pillar Two global minimum tax — a 15% top-up — applies to multinational groups with consolidated revenue of at least EUR 750 million, for accounting periods beginning on or after 1 January 2025.
- A transfer-pricing disclosure form is required from companies with revenue of at least THB 200 million.
- Tax residents are taxed on foreign-sourced income remitted to Thailand under Por. 161/2566, in force from 1 January 2024 — a proposed easing has been floated but is not yet law. A notable exception applies to LTR visa holders in the Wealthy Global Citizen, Wealthy Pensioner, and Work-from-Thailand categories, who are exempt under Royal Decree No. 743 (see our LTR Visa page).
What has changed lately.
- The Pillar Two top-up tax now caps the real value of low-rate incentives for large groups, and BOI relief measures — including a qualified refundable tax credit — are being introduced to soften the effect.
- The foreign-remittance rule (Por. 161/2566) remains fully in force; a proposed relaxation for income brought into Thailand within a set window has been discussed but not enacted.
- E-tax invoicing, e-receipts, and e-withholding tax continue to expand, steadily moving routine compliance onto digital channels.
How an engagement runs.
A clear sequence, from first look to ongoing review — so you know what each stage delivers and what it costs.
Scope & fact-gathering
We agree the question and gather what matters — recent returns, filings, and the shape of the group structure.
Exposure or health-check review
We test the current positions against Thai law and Revenue Department practice to map where risk and opportunity sit.
Recommendations
We set out the compliance gaps and the planning opportunities, with the risk of each weighed against the benefit.
Implementation
We execute the work — filings, rulings, refund claims, residency certificates, and transfer-pricing documentation.
Ongoing review
We keep positions current as the law and the business move, often on a quarterly cycle.
Most tax issues are upstream of the tax return — they're in the structure.
Once a structure is set, the tax filings follow mechanically. The leverage point is upstream: in the way the business is structured, the way intra-group transactions are priced, and the way cross-border flows are characterised.
We work with clients on transfer-pricing documentation, withholding-tax positions on royalties and management fees, double-tax treaty applications, BOI tax-holiday compliance, deemed-income exposures on cross-border employee secondments, and Revenue Department audit responses.
These engagements are scoped per matter rather than monthly. We work alongside whoever runs your routine compliance — including our own accounting team for clients on the standard package.
What we do
- Tax structuring at incorporation or restructuring
- Transfer-pricing documentation (Thailand Disclosure Form, Local File)
- Withholding-tax position memos (royalties, services, dividends, interest)
- Double-tax treaty applications and certificates of residence
- BOI tax-holiday compliance reviews
- Revenue Department audit defence
- VAT positions on cross-border services
- Personal income tax planning for senior expatriates
What you get
- Engagement scope agreed upfront — no open-ended advisory bills
- Memos written in defensible English with citation to Thai source law
- Coordinated with home-country counsel for cross-border transactions
How we work
Scoping
We agree the question, the deliverable (memo, opinion, filing), and the fee — usually fixed.
Analysis
Thai law research, comparison with current Revenue Department practice, coordination with foreign counsel if applicable.
Deliverable
Memo or opinion delivered with clear conclusions and recommended next steps.
Implementation
If the work leads to filings or registrations, we execute them; if it leads to a structural change, we coordinate with corporate secretarial.
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
Do I need transfer-pricing documentation?
Yes if your Thai entity has cross-border related-party transactions and revenue of THB 200 million or more in the accounting period. The Transfer Pricing Disclosure Form is filed annually with the corporate income tax return.
Can you defend a Revenue Department audit?
Yes — including drafting responses, attending audit meetings, and negotiating settlements where appropriate.
Are double-tax treaty benefits automatic?
No — they require a certificate of tax residence from the foreign jurisdiction and, in some cases, advance approval from the Thai Revenue Department.
How are advisory fees scoped?
Almost always as a fixed fee against a defined deliverable. We avoid open-ended hourly engagements where possible.
Reviewed by the Khonsu Legal team · 1 July 2026
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