Introducing the Orbitax International Tax Platform, a revolutionary suite of integrated tax solutions including research, compliance, calculations, entity management and charting. Find out more.
News Share

The Tax Hub

Daily Tax Newsletter


Responsive image

Thailand Enacts New Incentives Regimes for International Headquarters and International Trading Centers

Thailand enacted a new tax regime for International Headquarters (IHQ) and International Trading Centers (ITC) under Royal Decree No. 586 on 1 May 2015. The regime replaces the previous regime for Regional Operating Headquarters and International Procurement Centers, relaxing certain foreign ownership and activity limitations. Companies operating under the previous regimes may apply for the new regime incentives without claw back provisions.

Under the regime a company may be considered an IHQ and ITC depending on the qualifying activities it performs. The conditions are essentially the same and the benefits apply based on the activities of the company.

An IHQ is a company that provides management, technical and support services or treasury center services to associated companies or branches overseas. An ITC is engaged in trade and trade-related services.

Tax Benefits

The tax benefits provided include:

  • Tax exemption for 15 years on certain income derived from an overseas associated company or branch, including:
    • Income from providing management, technical, and support services;
    • Income from providing treasury center services;
    • Royalty income;
    • Dividend income;
    • Capital gains from the sale of shares of an associated company;
    • International trade, where the goods are not imported into Thailand (may be brought in as in transit or transshipment);
    • Trade related services; and
    • Other income generated by overseas branches
  • Reduced 10% income tax rate on certain income derived from an associated company or branch in Thailand, including income from:
    • Income from providing management, technical, and support services;
    • Income from providing treasury center services;
    • Royalty income;
  • Exemption from withholding tax on dividends distributed to nonresidents if paid out of exempt profits;
  • Exemption from business tax and withholding tax on intercompany loans; and
  • A reduced individual income tax flat rate of 15% for expatriate (foreign) employees

Qualifying management, technical and support services include:

  • General administration, business planning and coordination;
  • Procurement of raw materials and components;
  • Research and development of products;
  • Technical support;
  • Marketing and sales promotion planning;
  • Personnel management and regional training;
  • Financial advisory services;
  • Economics or investment research and analysis;
  • Credit control and administration; and
  • Other managerial services

Qualifying treasury center services include:

  • Services of a Treasury Centre as permitted under the Exchange Control Act; and
  • Borrowing from a Thai financial institution or associated enterprises in Thailand and re-lending in Thai currency the amount received from the above permitted activities to associated enterprises in Thailand

Qualifying trade and trade-related services include:

  • Procurement of goods;
  • Maintenance of goods in transit;
  • Packaging of goods;
  • Delivery of goods;
  • Insurance of goods;
  • Advisory and technical support services and training on goods; and
  • Other related services


In order to qualify as an IHQ or ITC and obtain the benefits, a company must submit an application to the Director-General of the Thai Revenue Department, and meet the following conditions:

  • The company must be incorporated in Thailand;
  • It must have paid-up capital of at least THB 10 million at the end of each accounting period;
  • It must provide qualifying services to overseas associated companies or branches; and
  • It must incur local operating expenses in Thailand of at least THB 15 million annually

Unlike the previous regime, if a company fails to meet the conditions in a particular year, the benefits will not apply for that year only. Under the previous regime, failure to meet the conditions would result in the benefits being clawed back from the first accounting year.

Powerful Tax Tools


FX Rates

Global FX Rates including Tax Year Average FX Rates and Spot Rates for all Reporting Currencies.


Corporate Tax Rates

Corporate tax rates, surtaxes, and effective tax rates for the current year, as well as historical rates and approved future rates.


Country Analysis

Detailed tax guidance for companies doing business in over 100 countries, including summaries and snapshots of key tax facts and issues.


Cross Border Tax Calculator

Calculate total tax costs and benefits of a cross border transaction including withholding tax, participation exemption and foreign tax credit rules.


Cross Border Tax Rates

Provides Domestic, treaty and EU cross border tax rates for over 5,000 country combinations for 9 different payment streams.



Complete overview of the OECD BEPS Project, including daily BEPS news, country adoption of BEPS measures, and an overview of the 15 BEPS Actions.


Tax Calendar

Customizable calendar tool that tracks corporate income tax, value added tax and transfer pricing obligations by country or entity.


Tax Forms

English translations of key tax forms for over 80 countries, including tax return forms, treaty benefit forms, withholding tax forms, and more.


Worldwide Tax Treaties

Repository including thousands of tax treaties (in English), OECD, UN and US Models, relevant EU Directives, Technical Explanations, and more.


Worldwide Tax Planner

Calculates the worldwide tax cost of what-if scenarios based on legal entity structure, taxable income, and cross border transactions.


Certified Rates Report

Customizable Certified Rates Report providing updated corporate and withholding tax rates at the end of each month for over 100 countries.


Withholding Tax Minimizer

Enables quick calculation of tax costs and benefits of cross border transactions considering all possible transaction combinations and optimal routes.


VAT Rates

Provides value added tax (VAT) rates, goods and services tax (GST) rates and other indirect tax rates for over 100 countries.


NOL Calculator

Country specific calculator to determine how net operating losses can be utilized in carryback and carryforward years.


Transfer Pricing Calculator

Calculates TP ratios under various TP methods and calculates the difference between target ratios and actual ratios.


Individual Income Tax Rates

Individual tax rates for over 100 countries.

Play of the Day

Crosss Border Rates

Provides Domestic, treaty and EU cross border tax rates for over 5,000 country combinations for 9 different payment Streams.

We’re here to help

We’re here to answer any questions you have about the Orbitax products and services.

Send us a message

Who’s behind Orbitax?

We’re committed to providing high value, low cost tax research and management solutions.

Learn More