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 purposed, 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 Income  Payee 1 Rate (%)
Commission and brokerage fees
  • Company/Registered partnership
  • Taxable foundation/association
3
10
Income from goodwill, copyrights, patents, trademarks, know-how or similar right
  • Company/Registered partnership
    Taxable foundation/association
 3
10
Interest on:
  • Bonds
  • Debentures
  • Commercial banks, finance, securities and credit foncier companies
1

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 Income  Payee 1 Rate (%)
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)
  • Taxable foundation/association
1

 

10

Dividend/Share of profit
  • Non-listed company 2/ Registered partnership
  • Listed company
  • Taxable foundation/association

10
Exempt
10

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 Income  Payee 1 Rate (%)
  • Rent 2
  • Company/Registered partnership
  • Individual/Unregistered partnership
  • Taxable foundation/association
5
5
10
  • Professional service fees (income from the practice of law, medicine, engineering, architecture or accounting)
  • Company/Registered partnership
  • Individual/Unregistered partnership
  • Taxable foundation/association

3
3
10

  • Income from contracting businesses
  • Company/Registered partnership
  • Individual/Unregistered partnership
  • “Permanent” branch of foreign corporation
  • “Non-permanent” branch of foreign corporation

3
3
3
5

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 Income  Payee 1 Rate (%)
  • Advertising income
  • Company/Registered partnership
  • Individual/Unregistered partnership
  • Taxable foundation/association
2
2
2
  • Awards from contests, competitions, or the like
  • Company/Registered partnership
  • Individual/Unregistered partnership
  • Taxable foundation/association

5
5
5

  • Awards, discounts, or other benefits given for sale promotion purposes (excluding those provided directly to end-users/consumers)
  • Company/Registered partnership
  • Individual/Unregistered partnership

3
3

  • Income from public entertainment
  • Public entertainer (resident)
  • Public entertainer (non-resident)2

5
5 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 Income  Payee 1 Rate (%)
  • Non-life insurance premium
  • Insurance companies
1
  • Transportation (excluding passenger fares from public transport)
  • Company/Registered partnership
  • Individual/Unregistered partnership

1
1

  • Service income from all other businesses than those stated above (excluding income from hotel and restaurant businesses and life insurance premiums)
  • Company/Registered partnership
  • Individual/Unregistered partnership

3
3

  • Sale of certain prescribed agricultural produce to manufacturers or exporters
  • Company/Registered partnership
  • Taxable foundation/association

0.75
0.75

1 “Company/Registered partnership” also includes commercial banks, and finance, securities and credit foncier companies.

Table 2

 Withholding tax on income paid by  “General companies”
 Type of Income  Payee 1 Rate (%)
  • Commission and brokerage fees
  • Company/Registered partnership
  • Taxable foundation/association
3
10
  • Income from goodwill, copyrights, patents, trademarks, knowhow or similar rights
  • Company/Registered partnership
  • Taxable foundation/association

3
10

  • Interest
  • Company/Registered partnership (excluding commercial banks, finance, securities and credit foncier companies)
  • Taxable foundation/association

1

10

  • Dividend/Share of profit
  • Non-listed company2/Registered partnership
  • Listed company
  • Taxable foundation/association

10
Exempt
10

  • Rent3
  • Company/Registered partnership
  • Individual/Unregistered partnership
  • Taxable foundation/association

5
5
10

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.
3 “Rent” included payments under finance lease agreements with effective from 1 June 2016

Table 2 (continued)

 Withholding tax on income paid by  “Banks and finance companies”
 Type of Income  Payee 1 Rate (%)
  • Professional service fees (Income from the practice of law , medicine, engineering, architecture or accounting)
  • Company/Registered partnership
  • Individual/Unregistered partnership
  • Taxable foundation/association
3
3
10
  • Income from contracting businesses
  • Company/Registered partnership
  • Individual/Unregistered partnership
  • “Permanent” branch of foreign corporation
  • “Non-permanent” branch of foreign corporation

3
3
3
5

  • Advertising income
  • Company/Registered partnership
  • Individual/Unregistered partnership
  • Taxable foundation/association

2
2
2

  • Awards from contests, competitions, or the like
  • Company/Registered partnership
  • Individual/Unregistered partnership
  • Taxable foundation/association

5
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 1 Rate (%)
  • Award, discounts, or other benefits given for sales promotion purposes (excluding those provided directly to end-users/consumers)
  • Company/Registered partnership
  • Individual/Unregistered partnership
3
3
  • Income from public entertainment
  • Public entertainment (resident)
  • Public entertainment (non-resident)2

5
5 to 37

  • Non-life insurance premium
  • Insurance companies

1

  • Transportation (excluding passenger fare from public transport)
  • Company/Registered partnership
  • Individual/Unregistered partnership

1
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 1 Rate (%)
  • 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 partnership
3
3
  • Sale of certain prescribed agriculture produce to manufacturer or exporter
  • Company/Registered partnership
  • Taxable foundation/association

0.75
0.75

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