Thailand in International Tax Planning

In this article, the authors explain the provisions in Thailand’s tax law that are designed to encourage foreign investment and economic development in the country. These include the participation exemption applicable to the taxation of foreign sourced dividends and capital gains under the holding company regime, and the international headquarters regime. The article addresses tax planning structures, which benefit from Thailand’s domestic law and tax treaties. The authors also discuss the current state of transfer pricing, adoption of BEPS initiatives and anti-avoidance rules in Thailand’s legislation.