On 24 Feb 2022, Thailand Tax Royal Decree (No 742) was gazetted adding to and extending the tax exemptions for corporate debt restructuring income.

This Royal Decree adds to and extends the Thailand Government's corporate tax relief measures that applied for the 2020 and 2021 years under Royal Decree (No 709). A summary of the tax relief measures under Royal Decree (No 742) follows.

Royal Decree (No 742) BE 2565

Applicability

From 01 January 2022 to 31 December 2026.

The Tax Exemptions

The tax exemptions granted under Royal Decree (No 742) are as follows:

For income derived from a transfer of assets, sale of goods or services and execution of instruments for a debt restructuring with a creditor that is a financial institution		Exemption from: - corporate income tax - value added tax - specific business tax and - stamp duty tax
For income derived from a forgive- ness of a debt by a creditor that is not a financial institution		Exemption from: - corporate income tax
For income derived from a transfer of assets, sale of goods or services and execution of instruments for a debt restructuring with a creditor that is not a financial institution		Exemption from: - corporate income tax - value added tax - specific business tax and - stamp duty tax
For income derived from a transfer of guarantor's immovable property pledged as collateral for a debtor's debt and execution of instruments for the debtor's debt restructuring with a creditor that is a financial institution		Exemption from: - corporate or personal income tax - specific business tax and - stamp duty tax
For income derived from a transfer of guarantor's immovable property pledged as collateral for a debtor's debt and execution of instruments for the debtor's debt restructuring with a creditor that's not a financial institution		Exemption from: - corporate or personal income tax - specific business tax and - stamp duty tax

The Rules and Conditions

The rules and conditions prescribed in Royal Decree (No 742) are that:

1. The debt restructuring shall be performed in accordance with the rules issued by the Bank of Thailand for debt restructurings; and
   
2. The business claiming the tax exemption shall comply with the Revenue Department's additional rules, procedures and conditions.

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