Thailand

Corporate residence is determined by the place of incorporation. A company incorporated under the laws of Thailand is a resident company.

A company incorporated abroad is subject to CIT in Thailand if it is considered to be carrying on business in Thailand. The term ‘carrying on business in Thailand’ is broad and, subject to the provisions of a DTT, includes the presence of an employee, representative, or go-between that results in the foreign company deriving income or gains in Thailand.