On 24 March 2025, Thailand Tax Royal Decree (No. 793) was gazetted, granting a corporate tax deduction concession to Thailand targeted industry businesses for employing Thai National Expats between 25 Mar 2025 and 31 Dec 2025.

This Insight summarizes the tax deduction concession under the RD (No. 793).

Thai National Expat

A Thai National Expat is a Thai national, who has at least a Bachelor's Degree of education, and who has been working overseas for at least two years.

Targeted Industry Business

A targeted industry business is a business of a Thailand corporate entity that has developed and uses or applies technology or innovation for production of goods and/or services, that the Government promotes under the laws governing target industries, investment promotion, and the Eastern Economic Corridor.

The Tax Deduction Concession under RD (No. 793)

Applicability

From 25 March 2025 to 31 December 2029.

The Tax Deduction Concession

For the costs incurred by a targeted industry business employing a Thai National Expat, a concessional corporate tax deduction of 150%, i.e.:

• The normal tax deduction for 100% of the salary costs, plus
• An additional tax deduction for 50% of the salary costs.

The Rules and Conditions

The rules and conditions prescribed in the Royal Decree (No. 793) are that:

1. The Thai National Expat shall:

1. Be a Thai national,
2. Possess an educational qualification of at least a bachelor's degree,
3. Have work experience in a foreign country of at least 2 years,
4. Not have been a resident of Thailand in the 2 tax years of 2023 and 2024 prior to the tax right under this Royal Decree commencing,
5. Not have worked in Thailand in the tax year of 2025 prior to the tax right under this Royal Decree commencing, 
6. Enter into an employment contract with a company operating a targeted industry business, which contract specifies a date for commencement of employment between 25 Mar 2025 and 31 Dec 2025,   
7. Enter Thailand for the purposes of working for the company operating a targeted industry business between 25 Mar 2025 and 31 Dec 2025,
8. Commence employment with the company operating a targeted industry business between 25 Mar 2025 and 31 Dec 2025, and
9. Be a resident of Thailand in the tax years during which the tax right under this Royal Decree is applicable except for the first and the last years of the tax right under this Royal Decree, and
10. Comply with the Revenue Department's additional rules, procedures, and conditions.

2. The company operating a targeted industry business:

1. Shall notify the employees entitled to the tax right under this Royal Decree by filing the prescribed form with the Revenue Department before the first payment being made to the employees,
2. Shall make payments to the employees entitled to the tax right under this Royal Decree for hire-of-labor income under Section 40 (1) of the Revenue Code,
3. Shall not exercise any other tax right under any other law or Royal Decree under the Revenue Code, and
4. Shall comply with the Revenue Department's additional rules, procedures and conditions.

Caution

If the Revenue Department's tax audit officers find any of the rules procedures or conditions have not been met, the entitlement to the concession may be lost and back-taxes plus penalty and surcharge could be payable.

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