New tax measures for Regional Office Headquarters

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The Revenue Department announced new tax measures for the companies registered as Regional Office Headquarters (‘ROH’).

Keywords: Tax, Regional Operating Headquarters (‘ROH’), Revenue Department

In order to be entitled to the tax privilege, companies must comply with following:

A 15 year corporate income tax holiday for net profits derived from overseas operations (previously 10% subject to the gross amount of overseas income being at least 50% of the ROH’s total income).
A corporate income tax rate of 10% for 15 years on the net profits derived from onshore operations.

Conditions

In the first year the ROH must have one operating company in another country; a second within the third year and a third within the fifth year.
Annual expenses in Thailand of at least Baht 15 million, or have invested at least Baht 30 million in Thailand.
By the end of the third year, 75% of ROH personnel to be qualified staff, have 5 specialised professionals, and 5 top executives each earning at least Baht 2.5 million per annum in salary and benefits;
All ROH must be operating companies with a physical presence and staff in Thailand.

15% personal income tax rate for 8 years for expatriate employees (previously 4 years).

Conditions

In addition to the conditions above:

Income generated from services to overseas companies must be at least 50% of the total revenue. This ROH tax measure was expected to be effective from 1st June 2010, however, no official announcement has been made thus far.

New tax measures for Regional Office Headquarters - Mazars - Thailand