VAT on imported services Thailand 2025: a reverse charge checklist for SMEs

gentlelawlawfirm
5 days ago
5 min read

Introduction

Buying offshore software, SaaS, cloud, media, or consulting that is used in Thailand can trigger local VAT through a reverse charge. Thai law deems services used in Thailand to be subject to VAT even when the provider is offshore, and it requires the Thai service recipient to file Form PP36 and remit VAT on behalf of the provider. The Revenue Department states this rule clearly and lists PP36 as the return for such cases.

At the same time, Thailand runs a separate VAT on Electronic Services regime for non resident e-service suppliers that sell to non-VAT registrants in Thailand. For B2B, the reverse charge still applies. For B2C that meets the VES criteria, the foreign platform registers and collects VAT itself.

Legal foundation you can cite

Reverse charge duty. Section 83/6 of the Revenue Code requires the payer to remit VAT when paying goods or services to certain persons, including service providers abroad whose services are used in Thailand.
Imported services rule. The Revenue Department’s VAT overview explains that services supplied from abroad and utilized in Thailand are subject to Thai VAT and the Thai recipient must file VAT 36.
Which form. The official English PP36 form confirms it is the “value added tax remittance return” used to remit VAT, including lines for surcharge and penalty when applicable.
Filing deadline. The PP36 instruction in Thai states the recipient must remit VAT within 7 days after the end of the month in which payment or liability arises, depending on the case.
E-filing extension window. Thai practice provides an 8 day extension for internet filing. KPMG’s 2025 Thailand tax calendar shows PP36 internet filing falling on the 15th of the following month when the paper deadline is the 7th. Always check monthly RD announcements when the last day shifts for holidays.
Penalties and surcharge. If you fail to pay or remit VAT on time, Section 89/1 imposes a 1.5 percent per month surcharge on the unpaid VAT, capped at the tax amount. Where a Director General extension applies, the rate reduces to 0.75 percent per month.
Input tax credit. For VAT registrants, VAT remitted via PP36 can be claimed as input tax in the VAT month you file PP36 and receive the RD receipt, per the Revenue Department’s order Por. 104/2544.

VAT on imported services Thailand 2025 checklist

Confirm it is an imported service Ask two questions: was the service performed abroad and are the results used in Thailand. If yes, VAT likely applies under Section 83/6. The RD VAT overview and annual reports use this same “used in Thailand” trigger.
Identify who files PP36The Thai service recipient files PP36 and remits VAT on behalf of the offshore provider. This rule applies whether or not the recipient is a VAT registrant.
Check if VES replaces PP36If the offshore provider is registered under the VAT on Electronic Services regime, it must charge VAT on sales to non-VAT registrants in Thailand. In that B2C scenario, the provider remits via the VES portal and the Thai customer does not file PP36. For B2B to a VAT registrant, the reverse charge still applies.
Work out the tax base and exchange rate Convert foreign currency to THB using methods allowed by the Revenue Code and RD orders. RD guidance refers to Section 79/4 and to specific exchange rate methods. For PP36, RD Order Por. 132/2548 illustrates use of a commercial bank selling rate on the payment day as an accepted method. Be consistent once you choose a method and keep evidence.
Calculate VAT at the current rate Multiply the THB base by 7 percent VAT. The RD VES materials confirm the 7 percent rate used in practice.
File and pay on time
- Paper deadline: by the 7th day of the month after the tax month.
- Internet filing: commonly the 15th with the 8 day extension. Verify each month in the RD tax calendar or notices.
Claim input tax if eligible Only VAT registrants may claim the PP36 VAT as input. Book it in the same tax month you filed PP36 and obtained the RD receipt.

Worked examples

Example A: B2B SaaS subscription

A Thai VAT registrant buys a monthly US dollar SaaS plan used by the Thai team.

Determine exchange rate following Por. 132/2548. Record the commercial bank selling rate on the payment day.
Calculate VAT at 7 percent and file PP36 for that month. Paper due the 7th, internet due the 15th if the extension applies.
Claim the VAT as input tax in the same month once the RD receipt is issued.

Example B: B2C streaming service for a non-VAT registered startup

A Thai company that has not yet registered for VAT buys an offshore streaming plan for marketing screenings.

If the provider is registered under VES, it charges 7 percent and remits directly. No PP36 filing is required by the Thai customer.
If the provider is not VES registered, the Thai customer must file PP36 and pay the VAT.

Common pitfalls we see and fix

Missing the 7th and 15th schedule. Failing to file on time triggers the 1.5 percent per month surcharge on the unpaid VAT. Track both paper and internet dates.
Wrong exchange rate source. Por. 132/2548 provides examples for PP36 exchange rate selection. Document your method and apply it consistently.
Claiming input without the RD receipt. Input is claimable only when you both file PP36 and have the RD receipt in the same tax month.
Confusing VES and PP36. VES covers non-VAT registrant customers. For VAT registrants, the reverse charge via PP36 usually applies even if the foreign platform is popular or automated.

Frequently asked questions

What counts as “used in Thailand” RD guidance states services used in Thailand are subject to VAT regardless of where they were performed. Examples include hosting, cloud, software subscriptions, marketing tools, or consulting where the benefit is in Thailand.

Is PP36 required if the invoice is issued to our Singapore parent Look at where the service is used and who pays. If the Thai entity uses the service or bears the cost, Thai VAT via PP36 often applies. See Section 83/6 on payer obligations.

Can a non-VAT registrant file PP36Yes. The Revenue Department’s VAT overview explains the service recipient in Thailand must file VAT 36 and remit VAT on the offshore service, even if not VAT registered. Input credit is not available to non-registrants.

Which VAT rate should I use in 2025Use 7 percent as reflected in current RD materials for e-service VAT and practice. Monitor official announcements in case of future changes.

How GENTLE LAW IBL executes and de-risks your PP36

Scoping. We map each vendor to Section 83/6 and the RD “used in Thailand” test, then decide PP36 versus VES.
Exchange rate memo. We select and document a compliant exchange rate method under Por. 132/2548 and Section 79/4 guidance so audits pass easily.
Calendar and claims. We file by the 7th or 15th as applicable and set up input claims under Por. 104/2544 for VAT registrants.

Call to action

If you want a clean, audit ready routine for VAT on imported services Thailand 2025, GENTLE LAW IBL will map each vendor, prepare PP36 packets with the correct exchange rate evidence, file on time, and maximize input recovery for VAT registrants.

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