Thailand income tax regime is governed by the Revenue Code of Thailand, which covers personal and corporate taxation. The Revenue Department, under the Ministry of Finance, administers the collection, enforcement, and policy implementation of all forms of national taxes.
Thailand applies a source-based taxation system, meaning income derived from within the Kingdom is generally taxable, regardless of the recipient’s tax residency. However, global income remitted into Thailand by tax residents is also subject to taxation.
II. Tax Residency and Scope of Taxation
| Status | Definition | Taxable Scope |
|---|---|---|
| Resident | Individual staying in Thailand ≥180 days/year | Income from all sources if remitted to Thailand |
| Non-Resident | Individual staying <180 days/year | Only income sourced in Thailand |
Thailand does not have a “green card” or permanent tax residency scheme; tax status is reassessed annually based on presence.
III. Categories of Taxable Income (Section 40 of the Revenue Code)
Thai law defines eight classes of assessable income:
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Employment income: Salaries, wages, commissions.
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Hire of work: Consulting or freelance income.
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Professional services: Architects, lawyers, etc.
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Contract work with tools/materials: Construction-type contracts.
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Royalties: Copyrights, intellectual property.
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Dividends, interest, capital gains (not all gains are taxable).
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Rental income: Immovable or movable property.
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Miscellaneous income: Prizes, gifts, annuities.
Income in foreign currency must be converted to Thai baht using the exchange rate on the date of receipt or remittance.
IV. Personal Income Tax Rates (Progressive Schedule)
| Net Annual Income (THB) | Tax Rate |
|---|---|
| 0–150,000 | Exempt |
| 150,001–300,000 | 5% |
| 300,001–500,000 | 10% |
| 500,001–750,000 | 15% |
| 750,001–1,000,000 | 20% |
| 1,000,001–2,000,000 | 25% |
| 2,000,001–5,000,000 | 30% |
| Above 5,000,000 | 35% |
Deductions, allowances, and exemptions apply (e.g., personal allowance, dependent allowance, insurance premiums), but the above table represents the gross bracket structure.
V. Corporate Income Tax (CIT)
| Entity Type | Tax Rate |
|---|---|
| General Thai Companies | 20% |
| SMEs (qualified) | 15–20% (graduated) |
| Foreign Companies (with PE) | 20% on income sourced from Thailand |
| Foreign Companies (no PE) | Subject to withholding tax on gross payments |
Permanent establishment (PE) is determined using OECD principles: fixed place of business, agents with authority to conclude contracts, or business operations conducted through Thai personnel.
VI. Withholding Tax System
Thailand employs a withholding tax mechanism whereby income payers must deduct and remit tax on behalf of the recipient:
| Income Type | WHT Rate |
|---|---|
| Dividends | 10% |
| Interest (individual) | 15% |
| Royalties | 15% |
| Rents | 5% |
| Services (to companies) | 3% |
| Employment Income | Progressive rates apply |
Non-compliance with withholding obligations triggers surcharges and penalties, including potential criminal liability for company directors.
VII. Tax Filing and Payment
Individuals
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Annual return (Form PND 90/91) due by March 31 of the following year.
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Online extensions may be available.
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Individuals with only income subject to withholding may not need to file if tax was fully collected.
Companies
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Annual CIT return (Form PND 50) within 150 days after fiscal year-end.
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Mid-year (interim) tax return (Form PND 51) due 2 months after the first 6 months of the fiscal year.
Late filing penalties: 2,000 THB fine plus 1.5% monthly surcharge on unpaid tax.
VIII. International Tax Aspects
Thailand has double tax agreements (DTAs) with over 60 countries, enabling:
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Relief from double taxation
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Reduced withholding tax rates
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Tax sparing for investment incentives
Treaty access requires proper certification and residency documentation, such as a foreign tax residency certificate.
Notably, Thailand is not part of the OECD CRS but does implement transfer pricing and anti-avoidance provisions under its Revenue Code.
IX. Recent and Emerging Issues
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Global Minimum Tax (GloBE Pillar 2): Thailand is exploring alignment for large multinational enterprises with 15% effective rate.
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Digital Economy Taxation: VAT registration is now required for foreign digital service providers (Netflix, Google, etc.).
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Crypto Taxation: Gains from cryptocurrency and digital assets are subject to PIT and specific reporting rules.
X. Enforcement and Audit Powers
The Revenue Department has extensive powers under Sections 17–23 of the Revenue Code to:
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Conduct desk or field audits
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Request bank and transaction records
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Issue assessments or corrections
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Impose surcharges up to 100% of underpaid tax
Taxpayer disputes may be appealed internally or taken to the Tax Court. Judicial review is possible under the Administrative Court system in cases of abuse of discretion.
Conclusion: Structured and Rules-Driven System
Thailand’s income tax regime is highly structured, residency-sensitive, and source-focused. While tax rates are regionally competitive, compliance requires navigating a layered regulatory framework, including withholding regimes, documentation obligations, and audit risks.
Professionals, expatriates, and corporate entities should proactively assess their tax positions, reporting obligations, and treaty eligibility to avoid penalties and maintain lawful standing.
