On 26 March 2019, the Thai Cabinet approved three Royal Decrees cancelling all tax incentives provided under the Regional operating headquarters (2010) regime (ROH), International headquarters regime (including Treasury Centres) (IHQ), International trade center regime (ITC). The repeal will become effective as of 1 June 2019 for corporate income tax incentives, and 1 January 2020 for personal income tax incentives
Cancelled as of 1 June 2019
- The reduction of Corporate Income Tax (CIT) rate and the exemption from corporate tax for income from the provision of services to affiliated companies, as well as for interest, royalties, and dividends received from affiliated companies;
- The reduction in the CIT rate and the exemption from corporate tax on income from trading activities and the provision of services related to international trade;
- The exemption from withholding tax on interest paid by the Treasury Centre to the foreign affiliate;
- The exemption from corporate income tax for gains derived from the disposal of shares in affiliated companies;
- The exemption from withholding tax for dividends paid to foreign shareholders, except for dividends paid out of profits derived before 1 June 2019, provided that the dividends are paid by 31 December 2020.
Cancelled as of 1 January 2020
- Cancellation of the Personal Income Tax (PIT) rate reduction applicable to foreigners from January 1, 2020 onwards;
- The withholding tax exemption on dividends paid to foreign shareholders (cancelled from 1 June 2019, except for dividends paid out of profits derived before 1 June 2019 provided that the dividends are paid by 31 December 2020);
The withholding tax exemption on interest paid by a Treasury Centre to a foreign recipient (the timing of cancellation requires clarification).
