Thailand PND 54 Filing 2026: Cross-Border WHT Guide for SMEs
Updated: 14 hours ago
Thailand PND 54 filing 2026 is one of the most important but most commonly missed tax processes for foreign SMEs in Thailand. It usually arises when a Thai payer makes income payments to a foreign company that is not carrying on business in Thailand, or when a foreign company disposes profits out of Thailand. The Revenue Department’s current English corporate income tax guidance still states that, for income paid to a foreign company not carrying on business in Thailand, the payer must withhold tax at source and file Form CIT 54, and that a company disposing profits out of Thailand must also pay tax using Form CIT 54.
This guide explains Thailand PND 54 filing 2026 in practical terms: when Section 70 applies, when Section 70 Bis applies, what the current filing deadlines are, how current e-Filing menus and tax calendar pages present PND 54, and how foreign SMEs can build a payment review process before funds leave Thailand.
Jurisdiction: Thailand.
Last reviewed: aligned with Thai law and practice as at 24 April 2026.
Thailand PND 54 filing 2026 under Section 70 and Section 70 Bis
The official P.N.D.54 form itself shows that it covers two distinct routes: Part A is “withholding tax under Section 70 of the Revenue Code” and Part B is “remittance of profits or amount treated as profits under Section 70 Bis of the Revenue Code.” That means Thailand PND 54 filing 2026 is not a single-purpose form. It is used both for outbound withholding on certain payments to foreign companies and for profit remittance situations.
Revenue Code Section 70, as published by the Revenue Department in English, says a company or juristic partnership incorporated under foreign laws and not carrying on business in Thailand but receiving assessable income under Section 40(2), (3), (4), (5), or (6) paid from or in Thailand is liable to tax, and the payer of income must deduct corporate income tax and remit it together with the prescribed return within 7 days from the last day of the month in which the income is paid.
Revenue Code Section 70 Bis says a company or juristic partnership disposing profits or money treated as profits out of Thailand must pay income tax by deducting tax from the disposed amount and remit it together with the prescribed return within 7 days from the date of disposal.
Current filing deadlines as of 2026
The Revenue Department tax calendar lists P.N.D.54 together with P.N.D.1, P.N.D.2, P.N.D.3, and P.N.D.53. It shows:
7th of the month as the filing date for standard paper filing
15th of the month as the internet filing date for withholding tax returns including P.N.D.54.
Key takeaways
Thailand PND 54 filing 2026 covers both Section 70 withholding on payments to foreign companies not carrying on business in Thailand and Section 70 Bis profit-remittance cases.
P.N.D.54 is due on the 7th of the following month for standard filing and the 15th for internet filing.
Treaties can reduce or exempt withholding, but documentation and eligibility must be verified prior to payment.
Call to action (GENTLE LAW IBL)
GENTLE LAW IBL can help foreign SMEs in Thailand design a practical outbound-payment review process for P.N.D.54, including payment-type classification, treaty review checkpoints, filing controls, and supporting-document packs that are ready for later certificate requests. Contact GENTLE LAW IBL at gentlelawibl.com.
