New tax measures for Regional Office Headquarters

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:

  1. Register the ROH within 5 years from the effective date; and
  2. 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.

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.

Personal income tax

  • 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.

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