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double taxation in thailand

Double Taxation

What is double taxation? How to avoid its effects to individuals and business entities?


Double taxation is a case where tax is being levied twice from the same amount of income in two or more states, e.g. Thailand and other countries.

In order to avoid or eliminate double taxation, Thailand has entered into Double Taxation Agreement with other countries. Currently, Thailand has agreement with 55 countries whereas both residents of Thailand and the contracting states will benefit from the agreement.

In a double taxation agreement, there are credit and exemption methods. It also covers taxes on income and capital of individuals and juristic entities as well as the petroleum income tax. The petroleum income tax and the local development tax (i.e. Property tax) are covered under some treaties but Value Added Tax, Specific Business Tax and Municipal Tax are not covered under any tax treaties.

Thai double taxation treaties generally place a resident of the Contracting State in a more favorable position for Thai tax purposes than under the domestic law, i.e. the Thai Revenue Code. Thus, in the event that the rate of tax stipulated in the Revenue Code is different from that of a double taxation agreement, the rate which is more beneficial to the taxpayer will be applied.

Thai double taxation treaties in general provide income tax exemption on business profits (industrial and commercial profits) earned in Thailand by a resident of a Contracting State if it does not have a permanent establishment in Thailand. Moreover, the withholding taxes on payments of income to foreign juristic entities not carrying on business in Thailand may be reduced or exempted under the double taxation treaties.

Contact MSNA for your Thai accounting and tax questions and other business needs.

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List of countries which concluded tax treaty agreement with Thailand

To avoid double taxation, Thailand has concluded tax treaty agreements with certain countries. As of March 2021, the countries which currently have tax treaties with the Kingdom are as follows:

  1. Armenia
  2. Australia
  3. Austria
  4. Bahrain
  5. Bangladesh
  6. Belarus
  7. Belgium
  8. Bulgaria
  9. Canada
  10. Cambodia
  11. Chile
  12. China P.R.
  13. Cyprus
  14. Czech Republic
  15. Denmark
  16. Estonia
  17. Finland
  18. France
  19. Germany
  20. Great Britain and Northern Ireland
  21. Hong Kong
  22. Hungary
  23. India
  24. Indonesia
  25. Ireland
  26. Israel
  27. Italy
  28. Japan
  29. Korea
  30. Kuwait
  31. Laos
  32. Luxembourg
  33. Malaysia
  34. Mauritius
  35. Myanmar
  36. Nepal
  37. The Netherlands
  38. New Zealand
  39. Norway
  40. Oman
  41. Pakistan
  42. Philippines
  43. Poland
  44. Romania
  45. Russia
  46. Seychelles
  47. Singapore
  48. Slovenia
  49. South Africa
  50. Spain
  51. Sri Lanka
  52. Sweden
  53. Switzerland
  54. Chinese Taipei
  55. Tajikistan
  56. Turkey
  57. Ukraine
  58. United Arab Emirates
  59. United States of America
  60. Uzbekistan
  61. Vietnam

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