The Thailand international payments withholding tax rates are the rates that are prescribed in Section 70 of the Thailand Revenue Code, as reduced or exempted under a Thailand Double Tax Agreement.

WHT Rates under Thailand's Revenue Code

As prescribed in Thailand's Revenue Code Section 70: When a payer in Thailand pays a specified type of income to a corporate entity established under a foreign law not carrying on business in Thailand, the payer shall withhold tax from the payment and remit the WHT to the Thailand Revenue Department.

The types of payments under Section 70 and their withholding tax rates are:

For international payments of dividend/share of profits income		10% WHT
For international payments of services income, royalty income, rights income, interest income, capital gains income, property & equipment rental income, and professional services income		15% WHT

WHT Rates under Thailand's DTAs

Royal Decree (No 18) issued under the Revenue Code prescribes: There shall be allowed reductions or exemptions from tax under the Revenue Code to persons entitled thereto under Double Tax Agreements (DTAs) and generally, Thailand's DTAs permit the reductions or exemptions from tax as shown below (BUT EACH PARTICULAR DTA MUST BE REFERRED TO FOR WHAT'S SPECIFIED THEREIN).

For international payments of dividend/share of profits income

When the dividend/share of profits income is paid to a resident of a DTA country

No reduction of the 10% WHT under Section 70*

* But see the DTA with Taiwan for what's specified for dividend payments to Taiwan

For international payments of services income

Payments of services income fall under the DTA Business Profits Articles, which specify

Exemption from the 15% WHT under Section 70

For international payments of royalty or rights income

For DTAs that specify one same rate of tax for the different types of royalty payments		No reduction of the 15% WHT under Section 70
For DTAs that specify different rates of tax for the different types of royalty payments:
- When payments are a Copyright Royalty(1)		Reduction of the 15% WHT under Section 70 to 5%*
- When payments are a Patent Royalty		Reduction of the 15% WHT under Section 70 to 8%*
- When payments are a Know-How Royalty		Reduction of the 15% WHT under Section 70 to 10%*
- When payments are an Equipment Royalty		Reduction of the 15% WHT under Section 70 to 8%*

(1) Thailand's Copyright Act specifically defines computer programs as a Copyright
* Each particular DTA must be referred to for what's specified therein.

For international payments of interest income

When the interest income payment is to a financial institution or insurance company in the DTA country		Reduction of the 15% WHT under Section 70 to 10%*
When the interest income payment is not to a financial institution or insurance co in the DTA country		No reduction of the 15% WHT under Section 70

* Each particular DTA must be referred to for what's specified therein.

For international payments of capital gains income

When the capital gains income is derived from an alienation of immovable property in Thailand		No reduction of the 15% WHT under Section 70
When the capital gains income is derived from an alienation of shares in a company holding immovable property in Thailand		No reduction of the 15% WHT under Section 70*
When the capital gains income is derived from an alienation of moveable property in Thailand		Exemption from the 15% WHT under Section 70*

* Each particular DTA must be referred to for what's specified therein.

For international payments of property and equipment rental income

When the income is paid for the rental of immovable property in Thailand		No reduction of the 15% WHT under Section 70
When the income is paid for the rental of movable property in Thailand		As specified for a payment of an Equipment Royalty*

* Each particular DTA must be referred to for what's specified therein.

For international payments of professional services income

When the income paid to a professional is for the professional's services		Exemption from the 15% WHT under Section 70
When the income paid to a professional is a right-to-use the professional's copyright		As specified for a payment of a Copyright Royalty*

* Each particular DTA must be referred to for what's specified therein.

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