Thai Tax Law on Dividends (Dividend Tax)
💼 Companies established under Thai law that pay dividends to shareholders must withhold tax at source, as follows:
- Thai resident individuals
- Withholding tax rate: 10%
- Based on Section 50(2)(j) of the Revenue Code
- Non-resident individuals (who stay in Thailand for less than 180 days)
- Withholding tax rate: 10%
- Also under Section 50(2)(j)
3.Companies or juristic partnerships
- Registered in Thailand, or
- Foreign companies operating in Thailand
- Withholding tax rate: 10%, unless:
- The receiving company is a listed company or limited company that holds ≥25% voting shares of the paying company, and
- The paying company does not hold shares in the receiving company (directly or indirectly)
➤ In such case: No withholding tax required
Based on Revenue Department Order No. ท.ป.4/2528, Clause 5
4.Foreign companies not operating in Thailand
– Withholding tax rate: 10%
– Under Section 70, Revenue Code (Table (2)(c): income from dividends)
Reference No. 405645
Subject: Withholding tax on dividend payments to individual and corporate shareholders, both domestic and foreign.
💼 Corporate Income Tax: Section 34 BOI Tax Incentives
(Dividend Exemption for Promoted Businesses)
Dividends paid from businesses that have been granted tax exemption under Section 31 (BOI-promoted projects) are not subject to corporate income tax during the promotion period.
✅ Key Points under Section 34:
- Exemption applies only to dividends from BOI-promoted projects
- Dividends must be paid and received during the exemption period
- No withholding tax is required for these dividends
- If a company has profits from both BOI and non-BOI activities:
- May choose the source of dividends
- Must record it in meeting minutes
- If not specified, allocate dividends proportionally
Dividends may be paid in the form of shares, and still qualify for withholding tax exemption
