"New" ROH incentives for Regional Operating Headquarters (ROH) were officially enacted by Royal Decree at the end of 2010. The "current" ROH incentives remain in place, however, and an ROH company now may choose to operate under the "new" incentives or "current" incentives. A summary of the difference between the two schemes is as follows:
|
"Current" ROH incentives |
"New" ROH incentives |
|
|
|
|
|
|
|
|
|
|
10% tax for an unlimited period |
10% tax for 10 accounting periods for royalty income derived from R&D products developed in Thailand3 4 |
|
Exempt from taxation |
|
|
No provision for withholding tax on dividend payments |
No withholding tax on certain dividends paid to overseas corporate shareholders4 |
|
10% tax for an unlimited period |
10% tax for 10 accounting periods for interest income with respect to loans made to and then relent by the ROH3 4 |
|
Accelerated Ratio (25% of asset value in 20 years) |
Accelerated Ratio (25% of asset value in 20 years) |
|
No time limit |
By 15 November 2015 |
|
Corporate tax deductions and exceptions will not be available for the particular accounting period in which the ROH fails to qualify |
All corporate tax deductions and exceptions will be retroactively revoked starting with the ROH's first accounting period |
1 Such expenses or investments must be paid to payees in Thailand.
2 Qualifying services under the "current" and "new" incentives include: general management, business planning and co-ordination, procurement of raw materials and components, research and development of products, technical support, marketing and sales promotion planning, personnel management and regional human resources training, business advisory, economic and investment research and analysis, credit management and control, and other services approved by the Revenue Department on a case-by-case basis.
3 The 10 accounting period limit may be extended by an additional five accounting periods if the ROH entity meets all criteria under item 1 "Criteria" and has incurred cumulative operating expenses of over 150 million baht by the 10th accounting period paid to payees in Thailand.
4 Total income generated from servicing overseas associated enterprises or branches or in the form of royalties from such entities must represent at least 50% of total company income for this incentive to apply.