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4.3. Branch Profit (Deemed Remittance) Tax

Unless a tax treaty provides otherwise, the after-tax income of a Thai branch or permanent establishment (PE) that is remitted to the foreign head office attracts a 10% profit remittance tax. The tax is not due by the Thai branches of foreign financial institutions on account of the remittance of after-tax profits that are traceable to lending transactions to non-residents of funds obtained from abroad (so-called out-out transactions).