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Supreme Court – Marketing fee paid pursuant to international franchise agreement constitutes "royalty"

|Treaty Development|Thailand
Thailand

The Supreme Court recently issued a judgment that the marketing fee paid by a Thai franchisee would be subject to Thai withholding tax as the fee constituted royalty income.

In a typical international franchise scheme, the foreign franchisor would charge the Thai franchisee a franchise fee, which typically consists of a royalty for the intellectual property and a m…

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