"Thailand's reputation as a business-friendly country for foreign investment has made it a leading center of commerce in Southeast Asia."  The available tax incentives for certain business activities and relatively low tax rates for non-promoted companies, well-developed infrastracture, and more importantly, the ideal geographical location, has made Thailand an ideal destination for both service and certain industry sectors.  In this regard, the Thailand's Board of Investment (BOI) has improved the qualifications and incentives available to International Headquarters (ITCs) and International Trading Centers (ITCs).  For example, in order to qualify for IHQ (previously called as regional operating headquarters [ROH]), it is now required to supervise one associated enterprise only (as compared to the previous requirement of three associated enterprises).  Moroever, IHQ can now act as a treasury centre for its associated enterprises. The tax incentives offered by the Thai Revenue Department (TRD) include corporate income tax (CIT) exemption for 15 accounting periods covering the income derived from qualified services to its foreign associated enterprises; reduced personal income tax rate of 15% on gross income for its expatriate employees; and exemption from specific business tax for gross receipts arising from lending to its associated enterprises.  If the IHQ fails to meet certain qualification, the tax benefits will only affect such particular accounting period. Previously, the adverse effects retroact to prior accounting periods.  

ITC (as compared to the previous International Procurement Office [IPO]) can now trade finished goods (previously, IPO can only trade semi-finished goods).  Moreover, if the ITC is engaged in the Out-Out business (purchase and sale of goods outside of Thailand without bringing them into Thailand, except for transshipment or transit under the Thai Customs Law), such income is exempt from CIT for 15 accouonting periods.  The tax incentives are also offered by the TRD; meaning, a separate application for tax incenvtives has to be filed before the TRD.  Please contact us for further information.