Keywords: Tax, Regional Operating Headquarters (‘ROH’), Revenue Department
In order to be entitled to the tax privilege, companies must comply with following:
- Register the ROH within 5 years from the effective date; and
- Minimum capital paid up is Baht 10 million.
Tax privileges and conditions
Corporate income tax
- 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.
- 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.
Personal income tax
- 15% personal income tax rate for 8 years for expatriate employees (previously 4 years).
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.