Thailand Entire Business Transfers Tax
Update | September 2012
A Royal Decree and a Ministerial Regulation have been issued to amend the shareholder tax exemptions under Entire Business Transfer transactions.
From Sep 2012, transferor companies under an Entire Business Transfer transaction are exempt from tax only when they receive shares in the transferee company. This Tax Law Guide has been updated to reflect the issue of these two new laws.
An Entire Business Transfer is carried out by one or more companies transferring entire business assets, liabilities, rights and obligations to another company under a sale and purchase of business agreement, and then dissolving and entering into liquidation in the same accounting period as the transfer of the entire business.
The Revenue Code Prescriptions
For Entire Business Transfer transactions, the Revenue Code prescribes as follows:
The Revenue Department's Conditions
The conditions prescribed by the Director-General of Revenue are as follows:
This Tax Insight is general information only. It should not be used to determine any particular matter without consulting with an experienced Thailand tax advisor.