What an IBC does
Core activities are management, administrative, technical, support and treasury services to associated enterprises, plus certain international trading. Check the activity and associated-enterprise definitions in the rules in force.
Company registration services
International Business Center (IBC)
IBC: a Thai company providing management, technical or treasury services to associated enterprises may claim Revenue Code tax incentives when it meets Thai staff and expenditure conditions, and may separately seek BOI non-tax rights.
IBC tax incentives come from tax law and Revenue Department approval, while non-tax rights such as foreign ownership and foreign experts come from the BOI. One does not grant the other. This page checks the structure before filing and is not a tax ruling.
Information for a scope review
| Topic | Starting information | Review question |
|---|---|---|
| Group | Group chart and associated recipients | Whether recipients qualify as associated enterprises |
| Functions | Management, technical and treasury services | Activities that qualify as IBC |
| Substance | Staff, expenditure and premises in Thailand | Minimum conditions in Revenue rules |
Economic substance in Thailand
Tax conditions set minimum skilled employees and operating expenditure in Thailand. Real staff, premises and decision-making are needed; nominal arrangements risk losing incentives.
Tax and BOI rights are separate
Reduced rates and certain exemptions require Revenue Department approval; BOI promotion of IBC activity gives non-tax rights. Decide whether you need both or one.
Expatriate personal tax
Measures may include a special personal income tax rate for qualifying foreign executives or experts. Check individual eligibility and correct filing.
Transfer pricing and group records
Intra-group services need agreements, pricing and evidence of service. Prepare transfer-pricing documentation where required and align booked revenue with actual work.
Review every year
Incentives depend on meeting conditions each accounting period. Check headcount, spending and qualifying income before closing accounts and monitor rule changes.
Questions before preparing an application
- How does IBC differ from ROH?
- ROH is an earlier regime replaced by IBC; existing holders should check their transitional conditions.
- Does BOI IBC promotion give tax benefits?
- No. Tax incentives need separate Revenue Department approval and conditions.
- How many staff are required?
- As set in the current rules, which may vary by activity. Check the latest notice before planning.
- Can I serve non-associated clients?
- Income from non-associated parties usually does not qualify and must be accounted for separately.
- What should I prepare?
- Group chart, service list and recipients, Thai staffing and spending plan, and draft intra-group agreements.
- How can I obtain the service charges?
- Send the project details for scope review and request a written quotation. Any official charges are shown separately as published by the agency.
Official sources for requirement checks
- Revenue Department — tax information for investors
- Board of Investment (BOI) — announcements and activity lists
General preparation guidance. Check current announcements and project facts before filing; eligibility and approval are not assured.