Notice: Starting with December 2018, applications for International Trading Center (ITC) are no longer accepted.
The existing ITC companies that are currently receiving tax incentives may continue benefitting from these incentives until their approval expires (which is up to 15 years for an ITC). Alternatively, these companies have the possibility to either convert into an International Business Center (IBC) by filing an application at RD or apply for another BOI promotion, without being penalized for such termination.
An International Trading Center (ITC) is a company incorporated under Thai laws that purchases and sells (wholesale only) goods, raw materials and parts, or that provides international trading-related services to juristic persons incorporated under foreign laws.
International trading-related services include:
• Procurement of goods
• Warehousing and inventory services prior to delivery
• Packaging services
• Transportation of goods
• Insurance on goods
• Advisory, technical and training services on goods
• Any other services stipulated by the Director General of the Revenue Department
After-sales services are not permitted and require specific licensing.
An International Trading Center (ITC) receives the following incentives:
Incentives offered by the Board of Investment (BOI)
• Permission to bring in skilled personnel and experts into the Kingdom to work in investment promoted activities
• Permission to own land
• Exemption of import duty on machinery
• Exemption of import duty on raw materials and parts used in the production for export
Conditions to qualify for privileges offered by the BOI:
• Registered and fully paid-up capital of at least 10 million Baht
• Provision of services related to international trade that meet the criteria set for the promotion of ITC
Incentives offered by Revenue Department (RD)
Revenue entitled to corporate income tax exemption:
• Income derived from the purchase and sales of goods overseas (so called out-out transactions) on the condition that such goods must not be imported into Thailand, except for the purpose of transit or transshipment under Thai customs law
• Income derived from providing international trading related services to juristic persons established under foreign laws on the condition that such income must be received from or in foreign country
Corporate Income Tax (CIT) privilege will be granted for 15 accounting periods from the date of approval by the Director General of the Revenue Department.
Personal Income Tax
The personal income tax rate for expatriates working in an ITC, receiving a minimum salary of 2.4 million Baht per year and residing in Thailand for at least 180 days in each tax year (or 200,000 Baht per month if staying less than 1 years) is reduced to 15% (instead of progressive rates 0-35%) on gross income and benefits derived from employment.
Exemption from withholding tax for dividends paid by the ITC (dividends paid from revenue entitled to corporate income tax exemption) to a company or juristic partnership under foreign laws and has no operation in Thailand.
Conditions to apply for privileges offered by the Revenue Department:
• Paid-up capital must be at least 10 million Baht on the last day of each accounting period
• Total operating expenses which are paid to recipients in Thailand (excluding cost of sales) must be at least 15 million Baht per accounting period
In the calculation of Corporate Income Tax, the non-qualified income must be separated from the qualified income and its related expenses. In case the expenses cannot be separated, the ITC must allocate non-qualified and qualified expenses by the ratio of the received income or, with the approval of the Director General of the Revenue Department, use other ways of calculation.
If the ITC fails to fulfil any of the aforementioned conditions, the incentives will not be granted for that accounting year.
Existing International Procurement Offices (“IPO”) can change their status and become ITC.
In order to facilitate ITC registration for a foreign business certificate/license, the Department of Business Development has reduced the timeframe as follows:
• From 30 days to 15 days for BOI promoted companies
• From 60 days to 30 days for non-BOI promoted companies
The Bank of Thailand will also assist ITCs through a relaxation of foreign currency conditions.