Tax Section - Doing Business
You will find here a series of summaries providing an overview of useful tax regulations, processes and tax issues for Doing Business in Thailand.
The US Stance and the “Side-by-Side” Agreement
22 August 2025
The United States has adopted a unique and divergent position on Pillar Two. The current administration has formally withdrawn US support for the OECD’s global tax deal, issuing an executive order stating the agreement has “no force or effect” in the US without an act of Congress. This stance is rooted in concerns that the Pillar Two framework, particularly the Undertaxed Profits Rule (UTPR), infringes on US tax sovereignty and could grant other nations extraterritorial jurisdiction over American companies.
Thailand’s policy response to Pillar Two: BOI’s measures to sustain investment attractiveness
22 August 2025
With the upcoming implementation of the OECD’s Pillar Two framework, Thailand will begin applying a 15% global minimum tax (GMT) on large multinational enterprises (MNEs) from 1 January 2025. This marks a significant shift in international tax policy, aimed at ensuring a fairer distribution of tax revenues across jurisdictions.
New Thai tax ruling redefines treatment of foreign technology payments
22 July 2025
On 19 March 2025, the Thai Revenue Department issued Tax Ruling No. Gor.Kor.0702/1626, providing critical guidance on the tax treatment of payments made to foreign vendors for software and IT-related services.
Thailand considering to ease tax rules on foreign-sourced income
Under current rules effective from 1 January 2024, Thai tax residents, defined as individuals who reside in Thailand for 180 days or more in a calendar year, are required to report and pay personal income tax on any foreign-sourced income remitted into Thailand, regardless of the year in which that income was earned (unless the income was earned prior to 1 January 2024). This includes income from employment, dividends, interest, rental income, and capital gains derived overseas.
Streamlining withholding tax compliance: New framework for appointing qualified WHT agents
In practice, businesses acting as intermediaries, such as property managers, platform operators, or payment service providers, often face significant administrative burdens when managing payments received on behalf of multiple payers.