Thailand Regional Operating Headquarters (ROH) Tax
On 15 November 2015, the 5 years period of time allowed for submitting applications to the Thailand Revenue Department for entitlement to the concessions under the ROH 2 Regime ended. This Tax Insight has been updated by deleting the ROH 2 Regime concessions and conditions that were previously in this Insight. The concessions and conditions summarized herein are those of the original ROH 1 Regime, which continues to exist.
Thailand Regional Operating Headquarters Tax
In August 2002, the Government introduced tax concessions to encourage multinational and international corporations to establish a Regional Operating Headquarters (ROH) structure in Thailand. This Tax Insight summarizes the laws in Royal Decrees (No 405) and (No 406) that were issued on 5 August 2002.
An ROH is a company, which is incorporated in Thailand and which carries on a business of providing support services to a multinational's or international's affiliates in Thailand and in regional countries.
Support services is defined to include:
The Tax Concessions
(1) Tax concessions under Royal Decree (No 405):
(2) Tax concession under Royal Decree (No 406):
An ROH company claiming the tax concessions shall:
As a foreign company claiming tax concessions in Thailand an ROH company is rigorously investigated by the Revenue Department’s LTO (Large Taxpayers Office). If the LTO audit officers find that an ROH has not fully complied with each and every one of the prescribed rules, procedures and conditions, the ROH will lose its entitlements to the tax concessions and will be required to pay back-taxes at normal rates of tax plus penalties and surcharge.
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.