Withholding Tax Rates for Royalties
under Thailand's DTAs
if the recipient of royalties does not have a P.E. or fixed base in the source country
Country	Tax Rate not exceeding	Types of Royalties
1. Germany	5	use of or the right to use any copyright of literary, artistic or scientific work
	15	other royalties
		Note : also apply to the gains from the alienation of any right or property
		giving rise to such royalties if such right or property is alienated by a
		resident of a Contracting State for exclusive use in the other Contracting
		State and the payment of such right or property is borne by an enterprise
		of that other State or a permanent establishment situated therein
2. France	5	alienation or use of or the right to use any copyright of literary, artistic or
		scientific work
	15	other royalties
	Exempt	royalties or other like payments payable to a Contracting State or a
		State owned company in respect of films or tapes
	10	as long as the tax rate provided by the French law on the royalties
		received by a French resident as consideration for the alienation of,
		or the exclusive right to use any patent, process or information
		concerning industrial experience does not exceed 10 per cent,
		the tax charged in the Contracting State in which such royalties arise
		shall not exceed 10 per cent.
3. Singapore	15	all royalties
4. Netherlands	5	use of or the right to use any copyright of literary, artistic or scientific work
	15	other royalties
5. Korea	15	all royalties  (the term "royalties" does not include any royalties, rentals
		or other amounts paid in respect of the operation of mines, quarries
		or other natural resources)
6. Italy	5	use of or the right to use any copyright of literary, artistic or scientific work
	15	other royalties
7. Belgium	5	use of or the right to use any copyright of literary, artistic or scientific work
	15	other royalties
8. Pakistan	10	alienation or use or the right to use any copyright of literary, artistic
		or scientific work
	20	other royalties (Note:  For royalties arising in Thailand, apply 15% in
		accordance with the Revenue Code)
	Exempt	State owned company in respect of films or tapes
9. United Kingdomom	5	use of or the right to use any copyright of literary, artistic or scientific work
	15	other royalties
10. Malaysia	15	all royalties except any royalty or other amount paid in respect of
		motion picture films or of  tapes for radio or television broadcasting, or
		of the operation of a mine, oil  well,  quarry or any other place of
		extraction of natural resources or of timber or other forest produce
	Exempt	approved industrial royalties derived from Malaysia by a resident of
	in Malaysia	Thailand
11. Philippines	15	if the royalties are paid
		(1) by  an  enterprise registe#7B0421 with the Philippine Board of
		Investments and engaged in prefer#7B0421 areas of activities; or
		(2) by  an  enterprise  under  the  promotion of the Board of Investment
		of Thailand; or
		(3) in respect of cinematographic films or tapes for  television or
		broadcasting
	25	other royalties (Note: For royalties arising in Thailand, apply 15% in
		accordance with the Revenue Code)
12. Poland	5	alienation, use of or the right to use any copyright of literary, artistic or
		scientific work excluding cinematographic films or tapes for television
		or broadcasting
	15	other royalties
	Exempt	royalties or other like payments payable to a Contracting State or a
		State owned company in respect of films or tapes
13. Canada	5	copyright royalties and other like payments in respect of the production
		or reproduction of any literary, dramatic, musical or artistic work (but not
		including royalties in respect of motion picture films and works on film
		or videotape for use in connection with television)
		(alienation, the use of, or the right to use)
	15	all royalties
14. Finland	15	all royalties
15. India	15	all royalties
16. Austria	15	all royalties
17. China	15	all royalties
18. Sweden	15	all royalties
19. Hungary	15	all royalties
20. Australia	15	all royalties
21. Sri Lanka	15	all royalties
22. Japan	15	all royalties
23. Vietnam	15	all royalties
24. Czech Replubicublic	5	alienation or use of or the right to use any copyright of literary, artistic or
		scientific work, excluding cinematograph films or films or tapes used for
		radio or television broadcasting
	10	alienation of any patent, trademark, design or model, plan, secret
		formula or process
	15	other royalties
25. Switzerlandd	5	alienation or use of, or the right to use any copyright, artistic or scientific
		work, excluding cinematograph films or films or tapes used for radio or
		television broadcasting
	10	alienation of any patent, trade mark, design or model, plan, secret
		formula or process
	15	other royalties (However, Thailand shall tax at the rate not exceeding 10
		percent if Switzerland does not, according to its internal law, levy a tax
		at source on royalties paid to non-residents and for tax credit purposes,
		allows as a deductible expense 50 per cent of the gross amount of
		royalties
26. Israel	5	use of or the right to use any copyright of literary, artistic or scientific work
		excluding cinematograph films or films or tapes used for radio or
		television broadcasting
	15	other royalties
27. South Africaa	15	all royalties
28. Romania	15	all royalties
29. United States of  Americaes	5	use of or the right to use any copyright of literary, artistic or scientific work
		including software, and motion pictures and works on film, tapes or
		other means of reproduction for use in connection with radio or
		television broadcasting
	8	use of or the right to use industrial, commercial or industrial equipment
	15	other royalties
30. Laos	15	all royalties
31. Mauritius	5	use of or the right to use any copyright of literary, artistic or scientific work
		excluding cinematograph films and films, tapes or discs used for radio
		or television broadcasting
	15	other royalties
32. Luxembourgg	15	all royalties
33. Bangladesh	15	all royalties
34. Nepal	15	all royalties
35. Spain	5	use of, or the right  to use, any copyrights of literary, dramatic, musical
		artistic or scientific work, excluding cinematograph films or films or
		tapes used for radio or television broadcasting
	8	financial leasing for the use of, or the right to use, industrial, commercial
		or scientific equipment
	15	other royalties
36. New Zealandnd	10	use of or the right to use any copyright, any industrial, commercial or
		scientific equipment, any motion picure film or film or videotape or any
		other recording for use in connection with television, or tape or any other
		recording in connection with radio broadcasting; the reception of, or the
		right to receive, visual images or sounds or both & the use in connection
		with television or radio broadcasting, visual images or sounds, or both,
		transmitted by satellite or cable, optic fibre or similar technology
	15	other royalties
37. Denmark	5	use or the right to use any copyright of literary, artistic or scientific work
	15	other royalties
38. Uzbekistan	15	all royalties
39. Cyprus	5	use of or the right to use any copyright of literary, dramatic, musical,
		artistic or scientific work, including software, cinematograph films or
		or tapes used for radio or television broadcasting
	10	use of, or the right to use, industrial, commercial or scientific equipment
		or for information concerning industrial, commercial or scientific
		experience
	15	other royalties
40. United Arab Emratesb Emirates	15	all royalties
41. Bulgaria	5	use or the right to use any copyright of literary, artistic or scientific work
		excluding cinematography films and films, tapes or discs for radio or
		television broadcasting
	15	other royalties
42. Armenia	15	all royalties
43. Indonesia	15	all royalties
44. Norway	5	use or the right to use any copyright of literary, artistic or scientific work
	10	use or the right to use industrial, commercial or scientific equipment
	15	other royalties
45. Bahrain	15	all royalties
46. Oman	15	all royalties
47. Slovenia	10	use of or the right to use any copyright of literary, artistic or scientific work
		including motion pictures, live broadcasting, film, tape or other means
		of the use or reproduction in connection with radio and television
		broadcasting, and for the use of, or the right to use industrial,
		commercial or scientific equipment
	15	other royalties
48. Ukraine	15	all royalties
49. Turkey	15	all royalties
50. Hong Kong	5	use of, or the right to use, any copyright of literary, artistic or scientific
		work
	10	use of, or the right to use, any patent, trademark, design or model, plan,
		secret formula or process
	15	other royalties
51. Seychelles	15	all royalties
52. Kuwait	20	all royalties ( Note: For royalties arising in Thailand, apply 15% in accordance
		with the Revenue Code )