Corporate income tax in Thailand 2025 for foreign SMEs: rates, returns, deadlines, and transfer pricing

gentlelawlawfirm
Sep 17, 2025
3 min read

Introduction

Foreign-owned SMEs operating in Thailand must navigate corporate income tax rates, half-year and year-end returns, e-filing extensions, withholding obligations, and the transfer pricing disclosure form. This guide explains the essentials of corporate income tax in Thailand 2025 for foreign SMEs, with links to authoritative sources from the Thai Revenue Department and leading professional firms.

1) The rate of Corporate income tax in Thailand 2025 for foreign SMEs reliefs in 2025

Standard corporate income tax rate: 20 percent on net profits.
SME reduced brackets: Thai Revenue Department guidance continues to show SME brackets at 0 percent for the first 300,000 baht of net profit, 15 percent for 300,001 to 3,000,000 baht, and 20 percent above that level. Always confirm that your company meets the SME conditions before applying reduced brackets.

Non-resident receipts: Where a foreign company is not carrying on business in Thailand, Thai payers must withhold tax on certain payments, generally 15 percent for interest, royalties, service fees, and 10 percent for dividends unless a tax treaty provides relief.

2) Returns and due dates you must calendar

Annual corporate income tax return PND.50

Due date: within 150 days after the end of your accounting period. With e-filing the Ministry of Finance grants an extra 8 days through 31 January 2027. For a calendar-year company this means around 7 June with e-filing.

Half-year corporate income tax return PND.51

Due date: within 2 months after the end of the first six months of your accounting period. For a 31 December year end this is 31 August on paper or 8 September with e-filing during the current extension window.
Under-estimation rule: If the half-year estimate is more than 25 percent below the full-year profit without a justifiable reason, a 20 percent surcharge applies to the shortfall.

Monthly withholding returns snapshot

Thai payers generally file monthly WHT returns for payments to individuals or companies. With e-filing, the common due date is the 15th of the following month during the extension period. Map your relevant forms such as PND.3 or PND.53 to your payment types.

3) Transfer pricing disclosure form and documentation

Who must file the disclosure form: Companies with annual revenue of at least 200 million baht that have related parties must file a Transfer Pricing Disclosure Form together with PND.50, within 150 days after year end.
Local file on request: The tax authority may request transfer pricing documentation, and taxpayers must submit it within 60 days in most cases. Prepare contemporaneously to avoid scramble risk.
Penalties for late or missing TP disclosure: professional guidance notes monetary penalties where the form is late or not filed. Keep evidence and internal controls aligned to the disclosure.

4) 2025 policy watch for larger groups

Thailand has announced it will implement a 15 percent global minimum tax for large multinational groups from 1 January 2025. This is not aimed at typical SMEs but is relevant if your group belongs to a consolidated MNE above the threshold.

5) Practical compliance checklist for foreign SMEs

Confirm whether you qualify for SME brackets or fall under the standard 20 percent corporate rate. Keep board minutes and paid-up capital records up to date to support SME status.
Build a calendar for PND.51 in August or two months after your mid-year, PND.50 at 150 days, and leverage the 8-day e-filing extension through 31 January 2027.
Monitor monthly WHT filings and match PND.3 or PND.53 to your payee types to avoid penalties.
If group revenue approaches 200 million baht, prepare the transfer pricing disclosure form with PND.50 and keep a ready local file for 60-day turnaround upon request.
Reconcile year-end actuals to your mid-year estimate to avoid the 20 percent under-estimation surcharge.

How GENTLE LAW IBL helps

Our one-stop team aligns entity structure, accounting, and tax filings for foreign-owned SMEs. We prepare PND.51 and PND.50, set up monthly withholding workflows, produce the transfer pricing disclosure form and local file, and defend positions with Revenue Department officers when required.

Conclusion and call to action

With the right calendar and controls, corporate income tax in Thailand 2025 for foreign SMEs is predictable. If you want a single partner to map your rates, filings, WHT, and transfer pricing, contact GENTLE LAW IBL for a compliance plan tailored to your sector.

📩 Book a consultation: https://gentlelawibl.com