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Thailand Corporate Income Tax (CIT) — PND.50/51 Filing & Planning

Companies in Thailand pay CIT at 20% of net profit — SME status trims it to 0-15% and BOI can waive it entirely for 3-8 years. NYC handles year-end audit, tax computation and filings for 200+ clients.

Clients
200+ firms
Standard CIT
20%
SME min.
0%
Service from
THB 12,000/y
Quick answer

The default CIT rate is 20% of net profit. SMEs (paid-up ≤ THB 5M + revenue ≤ THB 30M) enjoy 0% (profit ≤300K) / 15% (300K-3M) / 20% (above 3M). BOI grants 3-8 years of exemption. File PND.51 by end of August (mid-year estimate) and PND.50 within 150 days of year-end. NYC full-service starts at THB 12,000 per year.

2025 CIT rates by taxpayer type

Standard company 20%. SME (paid-up ≤5M + revenue ≤30M): 0% (profit ≤300K), 15% (300K-3M), 20% (>3M). BOI Cat A1-A4: 0% for 3-8 years. BOI Cat B1-B2: 50% reduction for 5 years. IHQ/ITC: 0-10%. Foundations/associations: 2% of gross receipts. Non-resident companies without a Thai PE: 15% WHT on interest/dividends.

Non-deductible expenses under §65bis

Entertainment for pleasure, fines, personal income tax of directors, entertainment above 0.3% of revenue (capped at THB 10M), donations above 2% of profit, and depreciation not aligned with statutory schedules. NYC pre-audits each line to avoid retroactive assessment for two prior years.

Loss carry-forwards (§65ter)

Business losses carry forward for five fiscal years (BOI 5-10 depending on the certificate). NYC schedules the recognition of revenues and reliefs to use losses before they expire.

Transfer Pricing (Act B.E. 2562)

Companies with revenue ≥ THB 200M and related-party transactions must file the TP Disclosure Form within 150 days, prepare a Local File within 60 days of Revenue Department request, and submit a Master File under CbCR rules. NYC's certified TP consultants deliver an OECD-aligned benchmark study.

BOI incentives

CIT holidays of 3-8 years by activity category (A1: 8 years uncapped; A2-A4: 3-8 years capped at investment amount), import-duty exemption on machinery and export raw materials, plus an additional 50% reduction for 5 years in Cat B. NYC's BOI OSS team files the promotion and tracks the certificate.

How it works

  1. 1. Close books & audit

    Consolidate ledgers, trial balance, adjustments, depreciation, inventory and receivables/payables. NYC coordinates with your CPA before signing off.

  2. 2. Taxable income calc.

    Add back non-deductible expenses (§65bis/ter), cap entertainment at 0.3%, apply tax-basis depreciation, use up 5-year loss carry-forwards, and apply SME/BOI reliefs.

  3. 3. File PND.51 mid-year

    Estimate half-year profits and pay 50% of the estimate — under-estimation by more than 25% triggers a 20% penalty plus 1.5%/month surcharge.

  4. 4. File PND.50 year-end

    Due 150 days after fiscal year-end (usually 30 May) with audited financials and Transfer Pricing Disclosure Form when applicable.

  5. 5. Transfer Pricing pack

    Revenue ≥ THB 200M with related-party transactions requires the TP Disclosure Form and a Local File within 60 days of Revenue Department request.

FAQ

SME has THB 5M capital but THB 35M revenue — still 20%?

Yes. The reduced SME rates apply only when both the paid-up capital and the annual revenue tests are met. Once either threshold is exceeded, the standard twenty percent corporate income tax rate applies to the whole taxable profit from the first baht, not just to the excess.

How costly is under-estimating PND.51 by more than 25%?

20% penalty on the shortfall plus 1.5%/month surcharge, unless a valid excuse (disaster) is accepted. NYC runs a sensitivity analysis to keep the estimate safe.

Can I combine SME and BOI benefits?

No — you must elect one. BOI is a full exemption while SME is a progressive rate; they are not stackable.

Penalty for late PND.50?

A late annual return attracts a criminal fine of up to THB 2,000, a surcharge of 1.5 percent per month on the tax due, and a penalty of up to 200 percent if the Revenue Department reassesses the figures. We send reminders thirty days before the filing deadline to avoid this stack of charges.

Company has 5 loss years — still file?

Yes — filing is mandatory every year regardless of tax due; otherwise a THB 2,000 criminal fine and forfeiture of loss carry-forwards apply.

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