Thailand

Corporate - Withholding taxes

Last reviewed - 14 January 2020

Withholding tax (WHT) rate schedule

Recipient WHT (%)
Dividends Interest Royalties
Resident corporations 0/10 (1) 0/1 (2) 3
Resident individuals 10 15 Progressive rates (3)
       
Non-resident corporations and individuals:    
Non-treaty 10 15 15
Treaty:      
Armenia 10 10/15 (4) 15
Australia 10 10/15 (4) 15
Austria 10 10/15 (4) 15
Bahrain 10 10/15 (4) 15
Bangladesh 10 10/15 (4) 15
Belarus 10 10/15 (5) 15
Belgium 10 10/15 (4) 5/15 (6)
Bulgaria 10 10/15 (4) 5/15 (7)
Cambodia  10 10/15 (4) 10 (8)
Canada 10 10/15 (4) 5/15 (9)
Chile 10 10/15 (4) 10/15 (10)
China 10 10/15 (4) 15
Cyprus 10 10/15 (11) 5/10/15 (12)
Czech Republic 10 10/15 (4) 5/10/15 (13)
Denmark 10 10/15 (4) 5/15 (6)
Estonia 10 10 8/10 (14)
Finland 10 10/15 (4) 15
France 10 3/10/15 (15) 0/5/15 (16)
Germany 10 0/10/15 (17) 5/15 (6)
Hong Kong 10 10/15 (18) 5/10/15 (19)
Hungary 10 10/15 (4) 15
India 10 10 10
Indonesia 10 10/15 (4) 15
Ireland 10 10/15 (18) 5/10/15 (20)
Israel 10 10/15 (4) 5/15 (21)
Italy 10 0/10/15 (22) 5/15 (6)
Japan 10 0/10/15 (23) 15
Korea, Republic of 10 10/15 (18) 5/10/15 (24)
Kuwait 10 10/15 (4) 15
Laos 10 10/15 (4) 15
Luxembourg 10 10/15 (4) 15
Malaysia 10 10/15 (4) 15
Mauritius 10 10/15 (4) 5/15 (7)
Myanmar 10 10 5/10/15 (25)
Nepal 10 10/15 (4) 15
Netherlands 10 10/15 (4) 5/15 (6)
New Zealand 10 10/15 (18) 10/15 (26)
Norway 10 10/15 (4) 5/10/15 (27)
Oman 10 10/15 (28) 15
Pakistan 10 10/15 (4) 0/10/15 (29)
Philippines  10 10/15 (4) 15
Poland 10 10/15 (4) 0/5/15 (30)
Romania 10 10/15 (4) 15
Russia 10 10/15 (31) 15
Seychelles 10 10/15 (4) 15
Singapore 10 10/15 (17) 5/8/10 (32)
Slovenia 10 10/15 (4) 10/15 (33)
South Africa 10 10/15 (4) 15
Spain 10 10/15 (4) 5/8/15 (34)
Sri Lanka 10 10/15 (4) 15
Sweden 10 10/15 (4) 15
Switzerland 10 10/15 (4) 5/10/15 (35)
Taiwan 5/10 (36) 10/15 (4) 10
Tajikistan 10 10 5/10 (6)
Turkey 10 10/15 (4) 15
Ukraine 10 0/10/15 (37) 15
United Arab Emirates 10 10/15 (4) 15
United Kingdom 10 10/15 (4) 5/15 (6)
United States 10 10/15 (17) 5/8/15 (38)
Uzbekistan 10 10/15 (4) 15
Vietnam 10 10/15 (4) 15

Notes

  1. The zero rate applies to a recipient company listed on the Stock Exchange of Thailand and any other limited company that holds at least 25% of the total shares with voting rights in the company paying the dividend without any cross shareholding.
  2. The 1% rate applies to interest paid to all resident corporations other than banks or finance companies, except where interest arises from bonds or debentures.
  3. The progressive rates refer to the PIT rates.
  4. The 10% rate applies to interest paid to a recipient that is a bank or financial institution (including an insurance company).
  5. The 10% rate applies to interest paid (i) to a recipient that is a bank or financial institution (including an insurance company) or (ii) with respect to indebtedness arising as a consequence of a sale on credit of any equipment, merchandise, or services.
  6. The 5% rate applies to royalties paid for the use of, or the right to use, any copyright of literary, artistic, or scientific work.
  7. The 5% rate applies to royalties paid for the use of, or the right to use, any copyright of literary, artistic, or scientific work, excluding cinematograph films and films, tapes, or discs for radio or television broadcasting.
  8. Fees for technical services, which fall under Article 13, are also subject to tax at the rate of 10%. Fees for technical services mean payments for managerial, technical, or consultancy services. In the case of Thailand, where the consideration paid for managerial, technical, or consultancy services falls under Articles 12 (royalties) and 13, the provisions of Article 13 shall apply.
  9. The 5% rate applies to copyright royalties and other like payments in respect of the production or reproduction of any literary, dramatic, musical, or artistic work, excluding royalties with respect to motion picture films and works on film or videotape for use in connection with television.
  10. The 10% rate applies to royalties paid for the use of, or the right to use, any copyright of literary, artistic, or scientific work, or for the use of, or the right to use, industrial, commercial, or scientific equipment.
  11. The 10% rate applies to interest paid (i) to a recipient that is a bank or financial institution (including an insurance company); (ii) in connection with the sale on credit of any industrial, commercial, or scientific equipment; or (iii) in connection with the sale on credit of any merchandise by one enterprise to another enterprise.
  12. The 5% rate applies to royalties paid for the use of, or the right to use, any copyright of literary, dramatic, musical, artistic, or scientific work, including software, cinematograph films or films, or tapes used for radio or television broadcasting; and the 10% rate applies to royalties paid for the use of or the right to use industrial, commercial, or scientific equipment or for information concerning industrial, commercial, or scientific experience.
  13. The 5% rate applies to royalties paid for the alienation or the use of or the right to use any copyright of literary, artistic, or scientific work, excluding cinematograph films or films or tapes used for radio or television broadcasting, and the 10% rate for the alienation of any patent, trademark, design, or model, plan, secret formula, or process.
  14. The 8% rate applies to royalties paid for the use of, or the right to use, industrial, commercial, or scientific equipment. The 10% rate applies to royalties paid in all other cases.
  15. The 3% rate applies to interest paid on loans or credits granted for four years or more with the participation of a financing public institution to a statutory body or to an enterprise in relation to the sale of any equipment or to the survey, the installation, or the supply of industrial, commercial, or scientific premises and of public works. The 10% rate applies to interest paid to any financial institution.
  16. The zero rate applies to royalties paid to a contracting state or state-owned company with respect to films or tapes, and the 5% rate to royalties for the alienation or the use of or the right to use any copyright of literary, artistic, or scientific work.
  17. The zero rate applies to interest paid to any financial institution wholly owned by the other contracting state, a ‘land’, a political subdivision, a local authority, or a local administration thereof, and in particular, in the case of the Federal Republic, by the Deutsche Bundesbank or the Kreditanstalt für Wiederaufbau, and in the case of Thailand, by the Bank of Thailand. The 10% rate applies to interest paid to a recipient that is a bank or financial institution (including an insurance company).
  18. The 10% rate applies to (i) interest paid to any financial institution (including an insurance company) and (ii) interest paid with respect to indebtedness arising as a consequence of a sale on credit of any equipment, merchandise, or services, except where the sale was between persons not dealing with each other at arm’s length.
  19. The 5% rate applies to royalties paid for the use of, or the right to use, any copyright of literary, artistic, or scientific work and the 10% rate for the use of, or the right to use, any patent, trademark, design, or model, plan, secret formula, or process.
  20. The 5% rate applies to royalties paid for the use of, or the right to use, any copyright of literary, artistic, or scientific work, including software, and motion pictures and works on film, tape, or other means of reproduction for use in connection with radio or television broadcasting, and the 10% rate for the use of, or the right to use, industrial, commercial, or scientific equipment or any patent.
  21. The 5% rate applies to royalties paid for the use of, or the right to use, any copyright of literary, artistic, or scientific work, excluding cinematograph films or films or tapes used for radio or television broadcasting.
  22. The zero rate applies to interest paid to any financial institution wholly owned by the other contracting state, an administrative subdivision, or a local authority thereof. The 10% rate applies to interest paid to a recipient that is a bank or financial institution (including an insurance company).
  23. The zero rate applies to interest paid to any financial institution wholly owned by the government. The 10% rate applies to interest paid to a recipient that is a bank or financial institution (including an insurance company).
  24. The 5% rate applies to royalties paid for the use of, or the right to use, any copyright of literary, artistic, or scientific work, including software and motion pictures and works on film, tape, or other means of reproduction for use in connection with radio or television broadcasting, and the 10% rate for the use of or the right to use any patent, trademark, design, or model, plan, secret formula, or process.
  25. The 5% rate applies to royalties paid for the use of, or the right to use, any copyrights of literary, artistic, or scientific work, while the 10% rate applies to royalties for the consideration for any services of a managerial or consultancy nature, or for information concerning industrial, commercial, or scientific experience.
  26. The 10% rate applies to royalties paid for the use of, or the right to use, any copyright; or the use of, or the right to use, any industrial, scientific, or commercial equipment; or the use of, or the right to use, any motion picture film, or film or videotape or any other recording for use in connection with television, or tape or any other recording for use in connection with radio broadcasting; or the reception of, or the right to receive, visual images or sounds, or both, transmitted to the public by satellite or, cable, optic fibre, or similar technology; or the use in connection with television or radio broadcasting, or the right to use in connection with television or radio broadcasting, visual images or sounds, or both, transmitted by satellite or cable, optic fibre, or similar technology.
  27. The 5% rate applies to royalties paid for the use of, or the right to use, any copyright of literary, artistic, or scientific work, and the 10% rate applies to royalties paid for the use of or the right to use industrial, commercial, or scientific equipment.
  28. The 10% rate applies to (i) interest paid to a bank or financial institution (including an insurance company) and (ii) interest from a loan or debt claim that is guaranteed by the government.
  29. The zero rate applies to royalties paid to a contracting state or a state-owned company with respect to films or tapes, and the 10% rate applies to royalties paid for the alienation or the use of or the right to use any copyright of literary, artistic, or scientific work.
  30. The zero rate applies to royalties paid to a contracting state or a state owned company with respect to films or tapes. The 5% rate applies to royalties paid for the alienation or the use of or the right to use any copyright of literary, artistic, or scientific work, excluding cinematograph films or tapes used for television or broadcasting.
  31. The 10% rate applies to interest paid to the following recipients (i) in the case of a resident of Russia, any institution having a licence to carry on banking operations; and (ii) in the case of a resident of Thailand, any financial institution (including an insurance company).
  32. The 5% rate applies to royalties paid for the use of, or the right to use, any copyright of literary, artistic, or scientific work, including cinematograph films, or films or tapes used for radio or television broadcasting. The 8% rate applies to royalties paid for the use of, or the right to use, any patent, trademark, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial, or scientific equipment.
  33. The 10% rate applies to royalties paid for the use of, or the right to use, any copyright of literary or artistic work, including motion pictures, live broadcasting, film, tape, or other means of the use or reproduction in connection with radio and television broadcasting, and for the use of, or the right to use industrial, commercial, or scientific equipment.
  34. The 5% rate applies to royalties paid for the use of, or the right to use, any copyright of literary, dramatic, musical, artistic, or scientific work, excluding cinematograph films or films or tapes used for radio or television broadcasting. The 8% rate applies to royalties in consideration of financial leasing for the use of, or the right to use, industrial, commercial, or scientific equipment.
  35. The 5% rate applies to royalties paid for the alienation or the use of, or the right to use, any copyright, artistic, or scientific work, excluding cinematograph films or films or tapes used for radio or television broadcasting, and the 10% rate for the alienation of any patent, trademark, design or model, plan, secret formula, or process.
  36. The 5% rate applies if the recipient holds at least 25% of the capital of the company paying the dividend.
  37. The zero rate applies to interest paid to any other financial institution established and owned by the government to promote trade and investment. The 10% rate applies to interest paid to a recipient that is a bank or financial institution (including an insurance company).
  38. The 5% rate applies to royalties paid for the use of, or the right to use, any copyright of literary, artistic, or scientific work, including software, motion pictures, and works on film, tape, or other means of reproduction for use in connection with radio or television broadcasting. The 8% rate applies to royalties paid for the use of, or the right to use, industrial, commercial, or scientific equipment.