Withholding tax on income paid to Thai residents

Withholding tax on income Paid to Thai residents

(Pursuant to the Revenue Department’s Notification No. Taw Paw. 4/2528 as amended)

When making payments of income to Thai residents. companies and registered partnerships are required to withhold tax at various rates depending on the type of income and payee. For practical purposes, the withholding rates are summarised into two tables as follows.

Table 1:

Companies and registered partnerships are required to withhold tax at various rates depending on the type of income and payee. For practical purposes, the withholding rates are summarised into two tables as follows. This table summarises withholding tax rates for Income paid by companies and registered Partnerships other than commercial banks or finance, Securities and credit foncier companies (“General Companies”)

Table 2: This table summarises withholding tax rates for Income paid by companies and registered Partnerships other than commercial banks or finance, Securities, and credit foncier companies (“General Companies”)

Table 1
Withholding tax on income paid by“General companies” 
Type of IncomePayee 1Rate (%)
Commission and brokerage feesCompany/Registered partnership3
Taxable foundation/association10
Income from goodwill, copyrights, patents, trademarks, know-how, or similar rightCompany/Registered partnership3
Taxable foundation/association10
Interest on: Bonds  Commercial banks, finance, securities, and credit foncier companies1
Debentures
1 “Company/Registered partnership” also includes commercial banks, and finance, securities and credit foncier companies.
 
Table 1 (continued)
Withholding tax on income paid by“General companies” 
Type of IncomePayee 1Rate (%)
Interest on: – Bonds – Debentures – Bills – Loans – Difference between the redemption value and the selling price of a bill or a debt instrument issue by a juristic entity and sold for the first time at a price below its redemption value– Company/Registered partnership (other than commercial banks, finance, securities, and credit foncier companies)  1
– Taxable foundation/association10
Dividend/Share of profitNon-listed company 2/ Registered partnership10
Listed companyExempt
Taxable foundation/association10
1 “Company/Registered partnership” also includes commercial banks, and finance, securities and credit foncier companies.
2 No withholding is required if the recipient holds 25% or more of the payer’s equity and threr is no crossholding between them.
Table 1 (continued)
Withholding tax on income paid by“General companies” 
Type of IncomePayee 1Rate (%)
Rent 2Company/Registered partnership5
Individual/Unregistered partnership5
Taxable foundation/association10
 
Professional service fees (income from the practice of law, medicine, engineering, architecture or accounting)Company/Registered partnership3
Individual/Unregistered partnership3
Taxable foundation/association10
Income from contracting businessesCompany/Registered partnership3
Individual/Unregistered partnership3
“Permanent” branch of foreign corporation3
“Non-permanent” branch of foreign corporation5
1 “Company/Registered partnership” also includes commercial banks, and finance, securities and credit foncier companies.
2 “Rent” includes payment under finance lease agreement with effective from 1 June 2016.
   
Table 1 (continued)
Withholding tax on income paid by“General companies” 
Type of IncomePayee 1Rate (%)
Advertising incomeCompany/Registered partnership2
Individual/Unregistered partnership2
Taxable foundation/association2
 
Awards from contests, competitions, or the likeCompany/Registered partnership5
Individual/Unregistered partnership5
Taxable foundation/association5
 
Awards, discounts, or other benefits given for sale promotion purposes (excluding those provided directly to end-users/consumers)Company/Registered partnership3
Individual/Unregistered partnership3
 
Income from public entertainmentPublic entertainer (resident)5
Public entertainer (non-resident)25 to 37
1 “Company/Registered partnership” also includes commercial banks, and finance, securities and credit foncier companies.  
2 For non-resident actors hired by a non-resident company shooting a film authorised by the Film Board of Thailand, a flat rate of rate of 10% applies.
Table 1 (continued)
Withholding tax on income paid by“General companies” 
Type of IncomePayee 1Rate (%)
Non-life insurance premiumInsurance companies1
Transportation (excluding passenger fares from public transport)Company/Registered partnership1
Individual/Unregistered partnership1
Service income from all other businesses than those stated above (excluding income from hotel and restaurant businesses and life insurance premiums)Company/Registered partnership3
Individual/Unregistered partnership3
Sale of certain prescribed agricultural produce to manufacturers or exportersCompany/Registered partnership0.75
Individual/Unregistered partnership0.75
1 “Company/Registered partnership” also includes commercial banks, and finance, securities and credit foncier companies.
 
Table 1 (continued)
Withholding tax on income paid by“General companies” 
Type of IncomePayee 1Rate (%)
Commission and brokerage feesCompany/Registered partnership3
Taxable foundation/association10
ncome from goodwill, copyrights, patents, trademarks, knowhow or similar rightsCompany/Registered partnership3
Taxable foundation/association10
InterestCompany/Registered partnership (excluding commercial banks, finance, securities and credit foncier companies)1
Taxable foundation/association10
Dividend/Share of profitNon-listed company2/Registered partnership10
Listed companyExempt
Taxable foundation/association10
Rent3Company/Registered partnership5
Individual/Unregistered partnership5
Taxable foundation/association10
1 Unless expressly excluded, “Company/Registered partnership” also included commercial bank, and finance, securities and credit foncier companies.
2 No withholding is required if the recipient holds 25% or more of the payer’s equity and there is no crossholding between them.
Table 2 (continued)
 Withholding tax on income paid by “Banks and finance companies” 
 Type of Income Payee 1Rate (%)
Professional service fees (Income from the practice of law, medicine, engineering, architecture or accounting)Company/Registered partnershipIndividual/Unregistered partnershipTaxable foundation/association3
3
10
Income from contracting businessesCompany/Registered partnershipIndividual/Unregistered partnership“Permanent” branch of foreign corporation“Non-permanent” branch of foreign corporation3
3
3
5
Advertising incomeCompany/Registered partnershipIndividual/Unregistered partnershipTaxable foundation/association2
2
2
Awards from contests, competitions, or the likeCompany/Registered partnershipIndividual/Unregistered partnershipTaxable foundation/association5
5
5

1 Unless expressly excluded, “Company/Registered partnership” also includes commercial bank, and finance, securities, and credit foncier companies.

Table 2 (continued)
 Withholding tax on income paid by “Banks and finance companies” 
 Type of Income Payee 1Rate (%)
Awards, discounts, or other benefits given for sales promotion purposes (excluding those provided directly to end-users/consumers)Company/Registered partnershipIndividual/Unregistered partnership3
3
Income from public entertainmentPublic entertainment (resident)Public entertainment (non-resident)25
5 to 37
Non-life insurance premiumInsurance companies1
Transportation (excluding passenger fare from public transport)Company/Registered partnershipIndividual/Unregistered partnership1
1

1 Unless expressly excluded, “Company/Registered partnership” also included commercial bank, and finance, securities, and credit foncier companies.
2 For non-resident actors hired by a non-resident company shooting a film authorized by the Film Board of Thailand, a flat rate of 10% applies.

Table 2 (continued)
 Withholding tax on income paid by “Banks and finance companies” 
 Type of Income Payee 1Rate (%)
Service income from all other businesses than stated above (excluding income from hotel and restaurant businesses and life insurance premium)Company/Registered partnership Individual/Unregistered partnership3
3
Sale of certain prescribed agricultural produce to manufacturer or exporterCompany/Registered partnership Taxable foundation/association0.75
0.75

1 Unless expressly excluded, “Company/Registered partnership” also included commercial bank, and finance, securities, and credit foncier companies.