The new tax treaty will replace the existing 1975 Netherlands-Thailand income and capital tax treaty.
The Netherlands and Thailand signed a new income tax treaty on 21 November 2025 during the 4th EU Indo-Pacific Ministerial Forum (IPMF) in Brussels.
The new agreement aims to align with the latest international standards and implement recommendations from the OECD/G20 Base Erosion and Profit Shifting (BEPS) framework.
The treaty covers a range of taxes, including Dutch income, wage, corporate, and dividend taxes, as well as Thai income and petroleum taxes.
Key withholding tax rates under the new treaty include:
- Dividends: 10% on dividends from Thai-resident companies; 15% on dividends from Dutch-resident companies.
- Interest: 10% for financial institutions (including insurers), otherwise 15%.
- Royalties: 5% for copyrights of literary, artistic, or scientific works; otherwise 10%.
The treaty will enter into force after the exchange of ratification instruments. Once ratified and in force, it will replace the existing Netherlands-Thailand income and capital tax treaty, which has been in place since 1975.
Earlier, Thailand’s Cabinet approved the signing of the new tax treaty with the Netherlands on 24 December 2024.
