On 26 March 2019, the Thai Cabinet approved three draft royal decrees that will effectively end the grandfathering provided for the International Headquarters regime, the Regional Headquarters regime, the Treasury Center regime, and the International Trading Center regime, which were all replaced by the new International Business Center (IBC) regime (previous coverage). The old regimes were replaced by the IBC regime because they were found harmful as part of the OECD review in relation to BEPS Action 5.
With the introduction of the IBC regime, companies approved under the prior regimes were generally allowed to continue to apply the incentives until their approval expires. Subject to the completion of the legislative procedure and formal issuance of the royal decrees, the incentives of the old regimes will now expire on 1 June 2019. However, the individual income tax rate reductions for expatriate employees will expire 1 January 2020, and the withholding tax exemption on dividends paid to non-residents will continue to apply until 31 December 2020, provided the dividends are paid out of profits generated before 1 June 2019.
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