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Thailand Publishes Royal Decrees to End Grandfathering of Regimes Replaced by New International Business Centre Regime

Thailand has published a series of Royal Decrees in the Official Gazette that include provision to end the grandfathering provided for the Regional Operating Headquarters (ROH) regime (Royal Decree 685), International Headquarters (IHQ) regime (Royal Decree 686), and the International Trading Center (ITC) regime (Royal Decree 687), which were replaced by the new International Business Center (IBC) regime (previous coverage). The old regimes were replaced by the IBC regime because they were found to be harmful as part of the OECD review in relation to BEPS Action 5.

Some of the key points include the following:

  • In general, the reduced tax rate on qualifying income from affiliated enterprises in Thailand and the exemption on qualifying income from foreign affiliated enterprises is limited to income received before 1 June 2019 for ROHs and IHQs,
  • The preferential treatment for income from loans granted to affiliates by ROHs under the original 2002 regime will continue to apply up to the accounting period beginning on or after 1 January 2020 but not later than 31 December 2020;
  • The exemption on qualifying trading income of ITCs is limited to income received before 1 June 2019;
  • The beneficial tax treatment for foreign employees working in ROHs, IHQs, and ITCs will end 31 December 2019; and
  • The withholding tax exemption on dividends paid to non-residents applies for dividends paid up to 31 December 2020 out of profits derived from qualifying income before 1 June 2019, and for IHQs, exemption continues to apply for interest paid on loans received before 1 June 2019 to fund loans granted to affiliates.

The Royal Decrees entered into force on 2 November 2019.

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