Under Section 65 bis (10) of the Thai Revenue Code, dividends received from companies
or mutual funds incorporated under Thai law are exempted from income tax if the
recipient of the dividend is:

(a) A listed company; or

(b) A company holding at least 25% of total shares/units with voting rights in the
dividend payer, provided that the dividend payer does not have a directly or indirectly held shareholding interest in the dividend recipient.

In other case, the recipient of dividends is allowed to treat only one half of the
dividend revenue as assessable income for corporate income tax purposes.

However, the dividend recipient must hold the shares/investment units for at least three
months before and after the date the dividend is received (the so-called 3+3 rule).

Recently the Thai cabinet approved a draft Royal Decree that included dividend income
tax exemption / reduction for new companies formed by amalgamation or transferees
under an entire business transfer scheme.

Under a measure approved by the cabinet, when the dividends are received from new
companies formed by amalgamation or from the transferee under an entire
business transfer scheme, the period of time that the dividend recipient held
shares or units in the amalgamating companies or the transferor of business
before the amalgamation or business transfer can be taken into account in
determining the length of the shareholding.

For Thai taxation and accounting, contact MSNA, Thai accounting company in Bangkok.