| Withholding Tax Rates for Interest |
| under Thailand's DTAs |
| if the recipient of interest does not have a P.E. or fixed base in the source country |
| Country |
Recipient of interest |
Tax rate not exceeding |
Notes |
|
| 1. Germany |
financial institution incl. |
10 |
if the enterprise paying the interest |
| |
insurance companies |
|
engages in an industrial undertaking |
| |
other persons |
25 |
Note: for interest arising in Thailand, |
| |
|
|
apply 15% tax rate in accordance with |
| |
|
|
the Revenue Code |
| |
government and financial |
exempt |
|
| |
institution wholly owned |
|
|
| |
by the government |
|
|
| |
other persons |
exempt |
interest on bonds issued by the |
| |
|
|
government |
| 2. France |
other persons |
3 |
interest paid on loans or credits |
| |
|
|
granted for four years or more with the |
| |
|
|
participation of a financing public |
| |
|
|
institution to a statutory body or to an |
| |
|
|
enterprise in relation to the sale of |
| |
|
|
any equipment or to the survey, the |
| |
|
|
installation or the supply of industrial, |
| |
|
|
commercial or scientific premises and |
| |
|
|
public works |
| |
|
|
"Financing public institution" means in |
| |
|
|
the case of France, COFACE and |
| |
|
|
Natexis Bank and in the case of Thai- |
| |
|
|
land means EXIM Bank, Government |
| |
|
|
Savings Bank, Government Housing |
| |
|
|
Bank, Bank for Agriculture & Agricultu- |
| |
|
|
ral Cooperatives, Krung Thai Bank, |
| |
|
|
Rattanasin Bank, Industrial Finance |
| |
|
|
Corporation of Thailand |
| |
any financial institution |
10 |
|
| |
government |
exempt |
|
| 3. Singapore |
any financial institution |
10 |
|
| |
incl. insurance company |
|
|
| |
other persons |
25 |
Note: for interest arising in Thailand, |
| |
|
|
apply 15% tax rate in accordance with |
| |
|
|
the Revenue Code |
| |
government |
exempt |
|
| 4. Netherlands |
any financial institution |
10 |
|
| |
incl. insurance company |
|
|
| |
other persons |
25 |
Note: for interest arising in Thailand, |
| |
|
|
apply 15% tax rate in accordance with |
| |
|
|
the Revenue Code |
| 5. Korea |
any financial institution |
10 |
interest paid on debentures or on |
| |
incl. insurance company |
|
loans |
| |
government, central |
exempt |
|
| |
bank, or any agency or |
|
|
| |
insrumentality wholly |
|
|
| |
owned by that |
|
|
| |
government or that |
|
|
| |
central bank or both |
|
|
| 6. Italy |
any financial institution |
10 |
if the enterprise paying the interest |
| |
incl. insurance company |
|
engages in an industrial undertaking |
| |
government and financial |
exempt |
|
| |
wholly owned by the |
|
|
| |
the State |
|
|
| |
other persons |
exempt |
interest on bonds issued by the |
| |
|
|
government |
| 7. Belgium |
any financial institution |
10 |
|
| |
incl. insurance company |
|
|
| |
other persons |
25 |
Note: for interest arising in Thailand, |
| |
|
|
apply 15% tax rate in accordance with |
| |
|
|
the Revenue Code |
| |
government |
exempt |
|
| 8. Pakistan |
any financial institution |
10 |
|
| |
incl. insurance company |
|
|
| |
other persons |
25 |
|
| |
government |
exempt |
|
| 9. United Kingdom |
bank or financial institu- |
10 |
|
| |
tion incl. insurance |
|
|
| |
company |
|
|
| |
other persons |
25 |
|
| |
government, central |
exempt |
|
| |
bank or any agency |
|
|
| |
(other than agency with |
|
|
| |
share capital) wholly |
|
|
| |
owned by the govern- |
|
|
| |
ment |
|
|
| 10. Malaysia |
Malaysian financial insti- |
10 |
interest arising in Thailand |
| |
tution incl. insurance |
|
|
| |
company |
|
|
| |
other Malaysian persons |
25 |
Note: for interest arising in Thailand, |
| |
|
|
apply 15% tax rate in accordance with |
| |
|
|
the Revenue Code |
| |
Thai residents |
15 |
interest arising in Malaysia |
| |
government |
exempt |
|
| 11. Philippines |
Philippines financial in- |
10 |
interest arising in Thailand |
| |
stitution incl. insurance |
|
|
| |
company |
|
|
| |
other Philippines persons |
25 |
interest arising in Thailand |
| |
|
|
Note: for interest arising in Thailand, |
| |
|
|
apply 15% tax rate in accordance with |
| |
|
|
the Revenue Code |
| |
Thai residents |
10 |
interest arising in the Philippines in |
| |
|
|
respect of public issues of bonds, |
| |
|
|
debentures or similar obligations |
| |
Thai residents |
15 |
interest arising in the Philippines |
| |
government |
exempt |
|
| 12. Poland |
any financial institution |
10 |
|
| |
incl. insurance company |
|
|
| |
government |
exempt |
|
| |
|
|
Note: for other persons, apply |
| |
|
|
domestic tax rate (Thailand = 15%) |
| 13. Canada |
Canadian financial insti- |
10 |
interest arising in Thailand |
| |
tution incl. insurance |
|
|
| |
company |
|
|
| |
other Canadian persons |
25 |
Note: for interest arising in Thailand, |
| |
|
|
apply 15% tax rate in accordance with |
| |
|
|
the Revenue Code |
| |
Thai residents |
15 |
interest arising in Canada |
| |
government |
exempt |
|
| 14. Finland |
any financial institution |
10 |
|
| |
incl. insurance company |
|
|
| |
other persons |
25 |
Note: for interest arising in Thailand, |
| |
|
|
apply 15% tax rate in accordance with |
| |
|
|
the Revenue Code |
| |
government |
exempt |
|
| 15. India |
any financial institution |
10 |
|
| |
incl. insurance company |
|
|
| |
other persons |
25 |
Note: for interest arising in Thailand, |
| |
|
|
apply 15% tax rate in accordance with |
| |
|
|
the Revenue Code |
| |
government, local au- |
exempt |
|
| |
throity or central bank |
|
|
| 16. Austria |
any financial insitution |
10 |
|
| |
incl. insurance company |
|
|
| |
other persons |
25 |
Note: for interest arising in Thailand, |
| |
|
|
apply 15% tax rate in accordance with |
| |
|
|
the Revenue Code |
| |
government |
exempt |
|
| 17. China |
any financial institution |
10 |
|
| |
incl. insurance company |
|
|
| |
government |
exempt |
|
| |
|
|
Note: for other persons, apply |
| |
|
|
domestic tax rate (Thailand = 15%) |
| 18. Sweden |
any financial institution |
10 |
|
| |
incl. insurance company |
|
|
| |
any other company |
25 |
Note: for interest arising in Thailand, |
| |
|
|
apply 15% tax rate in accordance with |
| |
|
|
the Revenue Code |
| |
government or central |
exempt |
|
| |
bank |
|
|
| |
|
|
Note: for other persons, apply |
| |
|
|
doemstic tax rate (Thailand = 15%) |
| 19. Hungary |
any financial insitution |
10 |
|
| |
incl. insurance company |
|
|
| |
other persons |
25 |
Note: for interest arising in Thailand, |
| |
|
|
apply 15% tax rate in accordance with |
| |
|
|
the Revenue Code |
| |
government |
exempt |
|
| 20. Australia |
any financial institution |
10 |
|
| |
incl. insurance company |
|
|
| |
other persons |
25 |
Note: for interest arising in Thailand, |
| |
|
|
apply 15% tax rate in accordance with |
| |
|
|
the Revenue Code |
| |
government or central |
exempt |
Interest derived from the investment |
| |
bank |
|
of official reserves by the government |
| |
|
|
or by a bank performing central |
| |
|
|
banking functions |
| 21. Sri Lanka |
any financial institution |
10 |
|
| |
incl. insurance company |
|
|
| |
other persons |
25 |
Note: for interest arising in Thailand, |
| |
|
|
apply 15% tax rate in accordance with |
| |
|
|
the Revenue Code |
| |
government |
exempt |
|
| 22. Japan |
any financial institution |
10 |
|
| |
incl. insurance company |
|
|
| |
other persons |
25 |
Note: for interest arising in Thailand, |
| |
|
|
apply 15% tax rate in accordance with |
| |
|
|
the Revenue Code |
| |
government, central |
exempt |
|
| |
bank or financial insti- |
|
|
| |
tution wholly owned by |
|
|
| |
the government |
|
|
| 23. Vietnam |
any financial institution |
10 |
|
| |
incl. insurance company |
|
|
| |
other persons |
15 |
|
| |
government |
exempt |
|
| 24. Czech Republic |
any financial institution |
10 |
|
| |
incl. insurance company |
|
|
| |
government |
exempt |
|
| |
|
|
Note: for other persons, apply |
| |
|
|
domestic tax rate (Thailand = 15%) |
| 25. Switzerland |
any financial institution |
10 |
|
| |
incl. insurance company |
|
|
| |
other persons |
15 |
|
| |
other persons |
exempt |
if interest is paid in respect of a loan |
| |
|
|
made or guaranteed or insured by |
| |
|
|
the Bank of Thailand and EXIM Bank |
| |
|
|
or under the Swiss provisions |
| |
|
|
regulating the Export or Investment |
| |
|
|
Guarantee |
| 26. Israel |
any financial institution |
10 |
|
| |
incl. insurance company |
|
|
| |
other persons |
15 |
|
| |
government |
exempt |
|
| 27. South Africa |
any financial institution |
10 |
|
| |
incl. insurance company |
|
|
| |
other companies |
15 |
|
| |
government |
exempt |
|
| |
|
|
Note: for other persons, apply |
| |
|
|
domestic tax rate (Thailand = 15%) |
| 28. Romania |
any financial institution |
10 |
|
| |
incl. insurance company |
|
|
| |
other companies |
20 |
in the case of interest on credit sale |
| |
other companies |
25 |
|
| |
government |
exempt |
|
| |
|
|
Note: for other persons, apply |
| |
|
|
domestic tax rate (Thailand = 15%) |
| 29. United States of |
any financial institution |
10 |
|
| America |
incl. insurance company |
|
|
| |
other persons |
10 |
interest paid with respect to |
| |
|
|
indebtedness arising as a |
| |
|
|
consequence of a sale on credit of |
| |
|
|
any equipment, merchandise or |
| |
|
|
services |
| |
other persons |
15 |
|
| |
other persons |
exempt |
interest paid in respect of debt |
| |
|
|
obligations guaranteed or insured by |
| |
|
|
the government |
| |
government |
exempt |
|
| 30. Laos |
any financial institution |
10 |
|
| |
incl. insurance company |
|
|
| |
other persons |
15 |
|
| |
government |
exempt |
|
| 31. Mauritius |
any financial institution |
10 |
|
| |
incl. insurance company |
|
|
| |
other persons |
15 |
|
| |
government, institution |
exempt |
|
| |
body or board wholly |
|
|
| |
owned by the |
|
|
| |
government |
|
|
| 32. Luxembourg |
any financial institution |
10 |
|
| |
incl. insurance company |
|
|
| |
other persons |
15 |
|
| |
government |
exempt |
|
| 33. Bangladesh |
any financial institution |
10 |
|
| |
incl. insurance company |
|
|
| |
other persons |
15 |
|
| |
government |
exempt |
|
| 34. Nepal |
any financial institution |
10 |
|
| |
incl. insurance company |
|
|
| |
other companies |
15 |
|
| |
government |
exempt |
|
| |
|
|
Note: for other persons, apply |
| |
|
|
domestic tax rate (Thailand = 15%) |
| 35. Spain |
any financial institution |
10 |
|
| |
incl. insurance company |
|
|
| |
other persons |
15 |
|
| |
government |
exempt |
|
| 36. New Zealand |
any financial institution |
10 |
|
| |
incl. insurance company |
|
|
| |
other persons |
10 |
interest is paid with respect to |
| |
|
|
indebtedness arising as a |
| |
|
|
consequence of a sale on credit of |
| |
|
|
any equipment, merchandise or services |
| |
other persons |
15 |
|
| |
government |
exempt |
interest derived from the investment |
| |
|
|
of official reserves by the government, |
| |
|
|
a bank performing central banking |
| |
|
|
functions or EXIM Bank of Thailand |
| 37. Denmark |
financial institution incl. |
10 |
|
| |
insurance companies |
|
|
| |
other persons |
15 |
|
| |
government |
exempt |
|
| |
other persons |
exempt |
interest paid in respect of a loan made |
| |
|
|
by or guaranteed or insured by the |
| |
|
|
government, the central bank, or any |
| |
|
|
agency or instrumentality which is |
| |
|
|
wholly owned or controlled by that |
| |
|
|
government |
| 38. Uzbekistan |
any financial institution |
10 |
|
| |
incl. insurance company |
|
|
| |
other persons |
15 |
|
| |
other persons |
exempt |
if the interest is paid in respect of |
| |
|
|
loan made or guaranteed or insured1, or |
| |
|
|
in respect of any debt-claim or credit |
| |
|
|
guranteed or insured on behalf of the |
| |
|
|
the State by its authorised organ |
| |
government |
exempt |
|
| 39. Cyprus |
any financial institution |
10 |
|
| |
incl. insurance company |
|
|
| |
other persons |
10 |
interest is paid in connection with the |
| |
|
|
sale on credit of any industrial, |
| |
|
|
commercial or scientific equipment, |
| |
|
|
or of any merchandise |
| |
other persons |
15 |
|
| |
government |
exempt |
|
| 40. United Arab Emiratesrates |
any financial institution |
10 |
|
| |
incl. insurance company |
|
|
| |
other persons |
15 |
|
| |
other persons |
exempt |
if the interest is paid in respect of |
| |
|
|
loans guaranteed or insured by the |
| |
|
|
government |
| |
government |
exempt |
|
| 41. Bulgaria |
any financial insitution |
10 |
|
| |
incl. insurance company |
|
|
| |
other persons |
15 |
|
| |
government |
exempt |
|
| 42. Armenia |
Thai financial institution |
10 |
|
| |
incl. insurance company |
|
|
| |
Armenian institution |
10 |
|
| |
having a license to carry |
|
|
| |
on banking operations |
|
|
| |
government, authority |
exempt |
|
| |
created therein, the |
|
|
| |
Central Bank or the |
|
|
| |
EXIM Bank of Thailand |
|
|
| |
|
|
Note: for other persons, apply |
| |
|
|
domestic tax rate (Thailand = 15%) |
| 43. Indonesia |
Thai residents |
15 |
interest arising in Indonesia |
| |
Indonesian financial in- |
10 |
interest arising in Thailand |
| |
stitution incl. insurance |
|
|
| |
other Indonesian |
25 |
Note: for interest arising in Thailand, |
| |
residents |
|
apply 15% tax rate in accordance with |
| |
|
|
the Revenue Code |
| |
government |
exempt |
|
| 44. Norway |
financial institution incl. |
10 |
|
| |
insurance companies |
|
|
| |
other persons |
15 |
|
| |
government |
exempt |
|
| |
other persons |
exempt |
interest paid in respect of a loan made |
| |
|
|
by or guaranteed or insured by the |
| |
|
|
government |
| 45. Bahrain |
any financial institution |
10 |
|
| |
incl. insurance company |
|
|
| |
other persons |
15 |
|
| |
government |
exempt |
|
| 46. Oman |
any financial institution |
10 |
|
| |
incl. insurance company |
|
|
| |
other persons |
10 |
if the loan or debt-claim giving rise to |
| |
|
|
the interest is guranteed by the |
| |
|
|
government |
| |
other persons |
15 |
|
| |
government |
exempt |
|
| 47. Slovenia |
any financial institution |
10 |
|
| |
incl. insurance company |
|
|
| |
other persons |
15 |
|
| |
other persons |
exempt |
interest paid in respect of loan made |
| |
|
|
or guranteed by the government |
| |
government |
exempt |
|
| 48. Ukraine |
a bank or any other |
10 |
|
| |
financial institution incl. |
|
|
| |
investment banks and |
|
|
| |
savings banks and |
|
|
| |
insurance companies |
|
|
| |
other persons |
15 |
|
| |
other persons |
exempt |
interest with respect to debt-cliams |
| |
|
|
guaranteed, insured by the government |
| |
|
|
the central bank or any other financial |
| |
|
|
institution established and owned by |
| |
|
|
the government to promote trade and |
| |
|
|
investment |
| |
government, the central |
exempt |
|
| |
bank or any other |
|
|
| |
financial institution |
|
|
| |
established and owned |
|
|
| |
by the government to |
|
|
| |
promote trade and |
|
|
| |
investment |
|
|
| 49. Turkey |
any financial insitution |
10 |
|
| |
incl. insurance company |
|
|
| |
other persons |
15 |
|
| |
government |
exempt |
|
| |
|
|
|
| 50. Hong Kong |
any financial institution |
10 |
|
| |
or insurance company |
|
|
| |
other persons |
10 |
interest paid with respect to |
| |
|
|
indebtedness arising as a |
| |
|
|
consequence of a sale on credit of |
| |
|
|
any equipment, merchandise or |
| |
|
|
services |
| |
other persons |
15 |
|
| |
government |
exempt |
|
| 51. Seychelles |
any financial institution |
10 |
|
| |
other persons |
15 |
|
| |
government |
exempt |
|
| 52. Kuwait |
any financial institution |
10 |
|
| |
other persons |
15 |
|
| |
other persons |
exempt |
loans guaranteed or insured |
| |
|
|
by the government |
| |
government |
exempt |
|
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