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Tax Planning with Double Taxation Agreement’s in Practice

Tax Planning with Double Taxation Agreement’s in Practice. Chinawat Assavapokee 22 November 2011 . Foreign Company under Revenue Code. Place of Incorporation? Place of Management? Income Sourced in Thailand. Thai Income Tax of Foreign Company.

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Tax Planning with Double Taxation Agreement’s in Practice

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  1. Tax Planning with Double Taxation Agreement’s in Practice Chinawat Assavapokee 22 November 2011

  2. Foreign Company under Revenue Code • Place of Incorporation? • Place of Management? • Income Sourced in Thailand

  3. Thai Income Tax of Foreign Company • Carrying on business in Thailand (Section 66 and 76 bis) • Not carrying on business in Thailand but receive certain income paid in or from Thailand (Section 70)

  4. When does a foreign company carry on business in Thailand? • Branch Office(Section 66 paragraph 2) • Agent in Thailand(Section 76 bis)

  5. Branch Office • Income attributable to branch’s activities(Section 66 paragraph 2) [Attribution Rule] • Force of Attraction • Does DTA help?

  6. Force of Attraction Bank A Loan agreement Branch A B

  7. Example of Force of Attraction (1)1535/2520 - (Bank of America) (2) 3676/2528 - (Chase Manhattan Bank)

  8. Section 76 bis • No branch • Employee, Representative or Go-between in Thailand to deriveincome in Thailand

  9. Profit Remittance Tax - (Section 70 bis) • 10%

  10. Section 70 • Paid in or from Thailand • Income under Section 40(2)-(6) • Payee has to withhold tax

  11. Tax Rate • 15% • 10%Dividend DTA can help to minimize WHT

  12. Planning • Interest • Withholding Tax • How to minimize

  13. Rent • Capital Gain

  14. FORMOREINFORMATION Please contact: • Chinawat Assavapokee • Tax Partner, Baker & McKenzie • Tel: 02 636 2000 Ext. 3998 • Fax: 02 636 2111 bmca@bakermckenzie.com

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