On 27 October 2010, Royal Decree No. 508 (RD 508) was issued that added another package of tax incentives for Regional Operating Headquarters (ROH). With the advent of RD 508, a company may opt to apply for the old or new package of tax incentives. A company that wishes to apply for the new package is required to notify the Thai Revenue Department within 5 years from the date specified by the Director-General (to be announced later). RD 508 is effective from 28 October 2010 onwards and contains the following tax incentives and conditions:
|-||Reduction of corporate income tax (CIT) from the normal rate of 30% on net profits to 10% on net profits derived by the ROH on the following types of income:
|-||All the above incentives will be applicable for 10 consecutive accounting years. Such period may be extended for 5 years, provided that certain conditions are fulfilled.|
|-||CIT exemption on net profits derived from the services provided to the foreign affiliates and/or foreign branches.|
|-||Reduction of personal income tax (PIT) from the normal progressive rates ranging between 5%-37% to a flat rate of 15% for:
|-||CIT exemption for dividends received by ROHs from Thai/foreign affiliates.|
|-||CIT exemption for dividends received by a foreign entity (with no PE in Thailand) which are paid out from the net profits derived from "Qualified Incomes" (see the conditions below for the definition of the "Qualified Incomes".|
|-||No less than 50% of ROH's income must be composed of service fees and/or royalties on R&D received from offshore (Qualified Incomes).|
|-||The ROH must be a Thai company.|
|-||The ROH must have a paid up capital of no less than THB 10 million at the end of each accounting period.|
|-||The ROH must provide services to its affiliates and/or branch offices in at least:
|-||The ROH pays a Thai recipient a minimum of:
|-||The offshore affiliates or branches must actually carry out the businesses described in its objectives.|
|-||The ROH's employees must have the required level of education as announced by the Director-General of the Revenue Department (to be announced).|
|-||The ROH notifies the Thai Revenue Department of the claim for tax incentives within 5 years from a date to be specified by the Director-General (to be announced).|
|-||From the 3rd accounting year onwards, the following conditions must be fulfilled:
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