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Thailand to Amend International Headquarters and International Trading Centers Regimes to Limit Benefits for Royalty Income

26 June 2018

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Proposed Changes

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Thailand

The Thai Cabinet reportedly approved amendments on 19 June 2018 to the country's tax regimes for International Headquarters (IHQ) and International Trading Centers (ITC) in order to remove aspects of the regimes deemed harmful by the OECD as part of the work for BEPS Action 5. One of the main changes is a restriction on the benefits of the regimes for royalty income so that benefits will only apply in respect of royalty income resulting from research and development activity performed in Thailand. The two main benefits of the regimes that apply for royalty income include a tax exemption on...