Streamlining withholding tax compliance: New framework for appointing qualified WHT agents

RD Notification No. 457 Eases administrative burdens for multi-payer payment structures  

A common issue is the requirement to obtain separate withholding tax certificates for each transaction and each payer, which can lead to substantial operational inefficiencies, delays in tax credit claims, and increased risk of non-compliance.  

To address these issues, the Thai Revenue Department issued Notification of the Director-General of Revenue on Income Tax No. 457 (“DG.N. - IT. No. 457”) on 11 April 2025, introducing a formal framework that allows a company to act as a withholding tax agent (“WHT agent”) on behalf of multiple payers. The notification aims to reduce redundant withholding tax procedures, enhance tax reporting efficiency, and support evolving business models that involve centralized payment handling.  

Overview of the new withholding agent framework  

1. Formal appointment of an agent by contract  

A company may act as a WHT agent only if appointed by the payer through a written contract. The contract must: 

• Clearly designate the company as the WHT agent  
• Specify the effective and end dates of the appointment 
• Be affixed with an electronic stamp duty 
• Be retained by both the payer and the agent for review by tax authorities upon request  

2. System registration and access  

The appointed WHT agent must obtain access to the Revenue Department’s electronic tax platforms, such as the e-Filing system, the WHT Software Component: SWC, or the WHT Services System (SVS), to fulfill its filing obligations.  

3. Filing and disclosure requirements  

The WHT agent must: 

• Submit Form P.N.D. 53 electronically on behalf of the payer. 
• Include a notation in the tax invoice or receipt confirming that withholding tax has been deducted on the payer’s behalf.  

4. Claiming tax credits  

The WHT agent can rely on the P.N.D. 53 form filed with the Revenue Department, along with the official tax payment receipt, to claim a tax credit under Section 60 of the Revenue Code. This ensures that the delegation of withholding tax duties does not affect the agent’s entitlement to claim credit.  

5. Effective date and transitional measures  

The new rules apply to payments made from 1 July 2025 onwards. 

Existing contracts that extend beyond this date remain valid, provided that the documentation and reporting requirements under the new notification are met.  

Practical implications  

This regulatory update reflects the Revenue Department’s recognition of the practical difficulties faced by modern businesses in complying with traditional withholding tax requirements. By introducing a formal mechanism to appoint WHT agents, the Revenue Department enables a more streamlined, centralized, and technology-enabled approach to withholding tax compliance.  

This is particularly relevant for businesses operating in sectors such as real estate, logistics, e-commerce, and digital services, where payments are processed on behalf of multiple clients or users. Under the new rules, these businesses can now file withholding tax on behalf of their clients without the need to issue a separate tax certificate for every transaction, significantly reducing their compliance burden. 

Our observations  

DG.N. - IT. No. 457 represents a practical step forward in aligning Thailand’s tax administration with the operational realities of modern business models. It offers relief for companies that have to manage payments from numerous sources and reinforces the importance of electronic systems in achieving efficient tax compliance. As the 1 July 2025 effective date approaches, businesses intending to act as withholding tax agents should ensure that all contractual and system access requirements are in place.  

Forvis Mazars can assist clients throughout the process of setting up or being appointed as withholding tax agents. Our support covers the review of appointment agreements, guidance on system registration, and assistance with ongoing compliance and reporting obligations. Please feel free to reach out to our team if you would like to explore how the new framework can benefit your business.