This journey assumes
- The Japanese parent is an operating manufacturer, not a financial institution, and holds at least 25% (in practice usually all) of the Thai company.
- The Thai company will manufacture, assemble or process goods in an activity eligible for BOI promotion, and its activity is on List Two or List Three of the Foreign Business Act, or would be without promotion.
- The Thai company will import machinery and some components from Japan and export part of its output, including back to Japan.
- A small number of Japanese managers and engineers will be seconded to Thailand.
- Rules are stated as at 19 October 2026; BOI conditions are set project by project in the promotion certificate.
If any assumption is wrong for your business, the conclusions change. Ask WONE Global to re-run the analysis with your facts.
Both sides of the border, issue by issue
Each row is one part of the work. The left and right columns show what each country's rules require, so you can see where one side's decision constrains the other.
Leaving Japan and owning a Thai company
Japan places few limits on a manufacturer investing abroad: the investment is usually reported after the event. The real constraint is on the Thai side, where the Foreign Business Act restricts majority foreign-owned companies, and BOI promotion is the usual route to full foreign ownership for a manufacturer.
- Acquiring 10% or more of a foreign company is outward direct investment under the Foreign Exchange and Foreign Trade Act. For ordinary manufacturing it is in principle reported after the transaction rather than approved in advance; the form and deadline should be confirmed with the parent's bank.1
- Prior notification, with a 20-day waiting period, applies only to certain sensitive sectors such as fisheries, leather and weapons. A manufacturer outside those sectors should confirm its activity is not covered.2
- Transferring controlled machinery or technology to the Thai company can need METI export authorisation, which is separate from the investment report.3
- A company half or more owned by foreigners is a foreigner under the Foreign Business Act and cannot carry on restricted-list activities without a licence or certificate.4
- If the activity is BOI-promoted and on List Two or List Three, the company can obtain a Foreign Business Certificate for that activity, one of the routes to more than 49% foreign ownership.5
- BOI's own criteria impose no foreign equity limit for List Two and List Three activities, but require 51% Thai ownership for List One activities and allow the Board to set limits for particular activities.6
Board of Investment promotion
BOI promotion brings tax holidays, duty relief on machinery and materials, tax-free dividends from promoted profits, land ownership and an easier route for foreign experts. In return the project must meet the activity conditions, the minimum investment and the terms of its certificate. For a large group, the global minimum tax and Japan's CFC rules can reduce what a tax holiday is worth.
- A Thai subsidiary on a BOI tax holiday may have a tax burden below 20%, the trigger for Japan's CFC rules. If the subsidiary fails the active business tests all its income can be included in the Japanese parent's income, and certain passive income can be included even if it passes them.78
- The treaty deems Thai tax spared under specified sections of the Investment Promotion Act to have been paid when Japan gives credit. Its practical value now depends on how Japan taxes the income concerned, which should be checked with a Japanese adviser.910
- Groups with consolidated revenue of EUR 750 million or more face top-up tax that can offset a tax holiday; the BOI says it will keep its exemptions and is preparing a refundable tax credit.1112
- Corporate income tax exemption runs from 3 years (group A4) to 8 years (A1 and A2) or 10 to 13 years (A1+), with A2 to A4 capped at 100% of the investment excluding land and working capital.13
- Promotion can also exempt or reduce import duty on machinery and raw materials, and dividends paid out of promoted profits are exempt from income tax.1415
- Non-tax incentives include permission to own land and to bring in foreign skilled workers and experts; foreigners otherwise generally cannot own land.1617
- Each project needs at least THB 1 million of capital investment excluding land and working capital, unless the activity list sets a different figure.18
Forming the Thai company
The Thai subsidiary is normally a private limited company registered with the Department of Business Development. BOI promotion and the company registration run in parallel, and the minimum capital rules of the Foreign Business Act and of BOI both need checking.
- A private limited company needs at least two founders who sign the memorandum of association; the reserved name is valid for 30 days and the tax identification card must be obtained within 60 days.2021
- The Foreign Business Act sets minimum capital of THB 2 million, or THB 3 million for businesses needing permission, but BOI-promoted companies follow different rules, so the applicable figure should be confirmed with the BOI.2218
Tax on both sides and the Thailand-Japan convention
The Thai company pays 20% corporate income tax unless exempt under BOI promotion, charges 7% VAT and withholds 10% on dividends and 15% on royalties to Japan. In Japan, 95% of the dividend is excluded for a 25% holding. Related-party pricing must be supportable in both countries.
- Dividends from a Thai company held at 25% or more for six months are 95% excluded from Japanese tax; dividends deductible in Thailand would not qualify.10
- For income Japan does tax, such as royalties, Japan credits Thai tax under Article 21 of the convention, capped at the Japanese tax on that income.2324
- The CFC rules must be tested each year while the Thai company is on a tax holiday.78
- Corporate income tax is 20% of net profits and VAT is 7%, with registration above THB 1.8 million of turnover and exports zero-rated.2526
- Dividends to the Japanese parent bear 10% Thai withholding under domestic law, below the caps of 15% and 20% in the 1990 Thailand-Japan convention; dividends out of BOI-exempt profits are exempt.27281915
- Royalties and technical fees to Japan are withheld at 15%, and interest at 10% to banks or 15% to others.2724
- Companies with income of THB 200 million or more and related-party dealings file a transfer pricing disclosure form, and all companies file audited financial statements.2930
Moving machinery, parts and finished goods
Goods between Japan and Thailand can use the Japan-Thailand EPA, the ASEAN-Japan arrangements or RCEP, provided they meet the chosen agreement's origin rules. BOI duty relief on machinery and materials can matter more than the trade agreement for the start-up phase.
- The Japan-Thailand EPA has been in force since November 2007 and RCEP since 1 January 2022 for both countries; exporters choose the agreement that gives the better rate and whose origin rules the goods meet.3132
- Exports of controlled machinery or technology to the Thai plant may need METI authorisation.3
- Thailand lists Japan among its bilateral free trade partners and is a party to RCEP.3332
- BOI promotion can exempt or reduce import duty on machinery and on materials used for export production, independently of the trade agreements.14
Seconded staff, permits and social security
BOI-promoted companies bring in approved foreign experts through the Single Window for visas and work permits. Japan and Thailand have no social security agreement, so seconded Japanese staff may face contributions in both countries.
- Thailand is not among the 24 countries with which Japan has a social security agreement in force, so the exemptions such agreements give for seconded workers are not available.34
- Salary costs recharged by the Japanese parent for seconded staff should be priced and documented on both sides; Japanese payroll and pension treatment of seconded staff was not researched.29
- Foreign staff need a visa and a work permit before starting work; BOI-promoted companies obtain approval of expert positions and process visas and permits through the Single Window.353616
- Employer and employee each contribute 5% of wages to the Social Security Fund, subject to a wage ceiling.37
Funding, currency and repatriation
Capital goes into Thailand through banks licensed by the Bank of Thailand, and dividends, interest and loan repayments can go back to Japan freely once tax is withheld. Large export receipts must be brought back to Thailand within set periods.
- The capital injection is outward direct investment reported under the Foreign Exchange and Foreign Trade Act; dividends received are 95% excluded from Japanese tax.110
- Foreign exchange transactions must go through licensed institutions, mainly commercial banks, supervised by the Bank of Thailand.38
- Investment funds, loan repayments, dividends and interest can be remitted abroad up to the amount due; banks ask for documents for transactions of USD 200,000 or more unless a Know Your Business process has been completed.39
- Foreign currency receipts of USD 1 million or more, including export proceeds, must be brought back to Thailand within 360 days.40
Structures to consider
These are the structures businesses commonly weigh, not a recommendation. The right one depends on the facts listed under "What we need from you".
What has to happen first
- JapanBoard of the Japanese parent approves the Thai project, ownership plan and funding, and checks that the activity is not in a sector needing prior notification in Japan.
- ThailandCheck the activity against the BOI activity list (group A1+ to B), the Foreign Business Act lists and any BOI shareholding conditions.After step 1
- Both sidesModel the BOI tax holiday against Japan's CFC rules and, for large groups, the global minimum tax before relying on it.After step 2
- ThailandReserve the company name and incorporate the Thai private limited company, then obtain the tax identification card within 60 days.After step 1
- ThailandApply for BOI promotion for the project and accept the promotion on approval; obtain the Foreign Business Certificate where foreign ownership exceeds 49%.After step 2, 4
- Both sidesInject capital through a licensed Thai bank and file the Japanese outward direct investment report.After step 4
- ThailandApply for land ownership permission (or lease in an industrial estate) and for machinery import duty exemption under the promotion certificate.After step 5
- Both sidesObtain any METI export authorisation for controlled machinery or technology and confirm the origin rules under the Japan-Thailand EPA or RCEP for parts and finished goods.After step 1
- Both sidesApprove expert positions with the BOI and process visas and work permits for Japanese staff through the Single Window; settle their social security position in both countries.After step 5
- Both sidesSign intercompany agreements for parts supply, technical assistance, royalties and secondments, with a transfer pricing policy that works in both countries.After step 4
- ThailandRegister for VAT and the Social Security Fund and start production and trading.After step 7, 9, 10
- Both sidesOngoing: audited financial statements and corporate tax returns in Thailand, transfer pricing disclosure where income reaches THB 200 million, BOI condition reporting, Japanese CFC testing, and withholding on dividends and royalties paid to Japan.After step 11
What we need from you before anyone can advise
- The exact activity and products, which decide the BOI activity group, the Foreign Business Act list and the length of any tax holiday.
- Planned investment amount and how much is machinery, land and working capital.
- Group consolidated revenue (global minimum tax) and whether the Japanese parent's CFC position has been modelled.
- Share of output sold in Thailand, exported to ASEAN and exported to Japan, and the HS codes concerned.
- Whether the Thai company will pay royalties or technical fees to Japan and on what basis.
- How many Japanese staff will be seconded, for how long, and who will employ and pay them.
- Whether land will be bought under BOI permission or leased in an industrial estate.
- Whether a Thai partner is wanted or needed for any part of the business.
What this guide does not yet confirm
These points need checking with a qualified local professional before you rely on them.
- The Ministry of Finance and Bank of Japan pages on outward direct investment reports could not yet be checked; the reporting rule relies on a law-firm article and its form and deadline are unconfirmed.
- Articles 5 (permanent establishment), 11 (interest) and 12 (royalties) of the Thailand-Japan convention could not yet be checked on the official text; interest and royalty rates rely on a secondary source.
- No most-favoured-nation clause was seen in the treaty articles read, and whether the OECD multilateral instrument modifies the Thailand-Japan convention was not checked.
- The interaction between the treaty's indirect credit and tax sparing (Article 21) and Japan's 95% foreign dividend exclusion was not confirmed.
- Japan's CFC active business tests and how they apply to a BOI-exempt manufacturer could not yet be checked in the law; the CFC claims rely on a secondary source.
- The BOI application procedure (online system, Board approval, acceptance and certificate timelines) and post-promotion reporting duties were not confirmed.
- Whether the BOI Qualified Refundable Tax Credit has been enacted, and how Thailand's domestic top-up tax will treat BOI exemptions, were not confirmed.
- Japan-Thailand EPA rules of origin and certificate procedures could not yet be checked; the exact entry-into-force day was not stated on the page opened.
- Thai transfer pricing rules rely on a 2020 law-firm article; current Revenue Department guidance, documentation and deadlines could not yet be checked.
- Japanese payroll, pension and health insurance treatment of staff seconded to Thailand, and Thai personal income tax for them, were not researched.
Brief for your advisers
Questions to put to your advisers in each country. Copy them, or download them as a text file to send with your requirement.
- BOI adviser: which activity group does our project fall into, what tax holiday, duty exemptions and conditions can we expect, and what does the promotion certificate require of us?
- Thai corporate adviser: with BOI promotion, what foreign shareholding is allowed for our activity, which minimum capital applies, and do we need a Foreign Business Certificate?
- Japanese tax adviser: will a BOI-exempt Thai subsidiary be a CFC for us, can it pass the active business tests, and what passive income would be included?
- Japanese tax adviser: how will dividends, royalties and technical fees from Thailand be taxed in Japan, and does the treaty's tax sparing credit still help us?
- Both tax advisers: what transfer pricing policy should cover parts, finished goods, royalties and secondments between the two companies?
- Customs adviser: for our main HS codes, is the Japan-Thailand EPA or RCEP better, and how do BOI duty exemptions interact with them?
- Employment adviser: how do we keep Japanese pension and health coverage for seconded staff without a social security agreement, and what Thai contributions apply?
- Bank: what documents will you need for the capital injection, dividend and royalty remittances, and how do the export proceeds repatriation rules apply to us?
Who can help, on each side
Japan
- Setting up and running a company · Arranged by WONE Global on request
- Licences, permits and regulators · Arranged by WONE Global on request
- Payments and currency · Arranged by WONE Global on request
- Tax and structuring · Arranged by WONE Global on request
- Customs, trade and export controls · Arranged by WONE Global on request
- Accounting and annual filings · Arranged by WONE Global on request
- Employment, payroll and immigration · Arranged by WONE Global on request
- Banking and capital · Arranged by WONE Global on request
- Treasury and funding · Arranged by WONE Global on request
Thailand
- Setting up and running a company · Arranged by WONE Global on request
- Licences, permits and regulators · Arranged by WONE Global on request
- Payments and currency · Arranged by WONE Global on request
- Tax and structuring · Arranged by WONE Global on request
- Customs, trade and export controls · Arranged by WONE Global on request
- Accounting and annual filings · Arranged by WONE Global on request
- Employment, payroll and immigration · Arranged by WONE Global on request
- Banking and capital · Arranged by WONE Global on request
- Treasury and funding · Arranged by WONE Global on request
Sources and review status
Each statement is numbered to the source it was checked against. We use official sources where we can, and each statement says whether it was checked against an official or a secondary source. Sources last checked on 19 October 2026. None of it has been professionally reviewed yet: it is research checked against official and secondary sources by WONE Global, not legal or tax advice.
Under Japan's Foreign Exchange and Foreign Trade Act, outward direct investment by Japanese residents (broadly, acquiring 10% or more of the shares of a foreign company) is in principle subject to post-transaction reporting rather than prior approval. Japanese companies investing abroad. A further acquisition in a foreign company already held at 10% or more may be exempt where the transaction value is under JPY 1 billion. The source gives no reporting deadline.
Secondary source (law-firm article, undated). The Ministry of Finance and Bank of Japan pages on outward direct investment reports could not yet be checked; confirm the form and deadline with the Japanese parent's bank or adviser.
Outward direct investment in certain sensitive sectors, such as fisheries, leather, weapons or narcotics-related businesses, may require prior notification under the Foreign Exchange and Foreign Trade Act, with a standard waiting period of 20 days. Japan. Ordinary manufacturing outside these sectors is not described as needing prior notification.
Secondary source (law-firm article). The official list of designated sectors could not yet be checked.
Exports of goods and provision of technology may require prior authorisation from the Minister of Economy, Trade and Industry (METI). Controlled items and technologies.
Law-firm article, undated on the page; Ministry of Finance and Bank of Japan FEFTA pages could not be fetched (URL not reachable from this research tool). Confirm against official guidance.
Under the Foreign Business Act B.E. 2542 (1999), a company in which foreigners hold half or more of the shares is treated as a foreigner and may not carry on activities in the Act's three restricted lists without a Foreign Business Licence or certificate. List 1 activities are closed to foreigners; Lists 2 and 3 need permission. Many service activities fall under List 3.
List Three includes other service businesses except those exempted by ministerial regulation.
A foreigner whose List Two or List Three business is promoted by the Board of Investment can obtain a Foreign Business Certificate for that business, which is one route to more than 49 percent foreign ownership. Applies only to the promoted activity and subject to BOI conditions; industrial estate and export permissions follow the same certificate route.
Corrected on source check: the AI-written version also said the certificate comes with tax and non-tax incentives, which Section 12 does not address. The BOI 2026 quick guide lists the certificate as one of three routes above 49 percent.
BOI criteria require Thai nationals to hold at least 51% of the registered capital of projects in activities on List One of the Foreign Business Act, while for List Two and List Three activities there are no equity restrictions for foreign investors except as specified in other laws. BOI-promoted projects. The Board may set specific shareholding limits for particular activities, so the activity's own conditions must be checked.
Japan's controlled foreign company rules apply to foreign companies more than 50% owned by Japanese companies or residents, with a trigger tax rate of 20% (27% for paper companies for tax years beginning on or after 1 April 2024). A Japanese company with a 10% or more direct or indirect interest may have to include its share of the CFC's taxable retained earnings.
Secondary source.
Where a CFC's foreign tax rate is below 20%, all its income is aggregated if its main business fails the active business tests, and certain passive income is aggregated even if it passes them. The active business criteria are set out in Japanese law and could not yet be checked.
Secondary source.
Article 21(3) and (4) of the Thailand-Japan convention deem Thai tax to include tax that would have been paid but for exemptions or reductions under specified sections of the Investment Promotion Act (sections 31, 33, 34, 35(2), 35(3), 35(4) and 36(4)), a tax sparing credit. The provisions refer to the Act as in force at signature; the sparing for sections 35(3) and 36(4) stops after the thirteenth taxable year from the first grant. Article 21(5) caps the credit for dividends, royalties or similar proceeds at 25% of the gross amount.
Whether the sparing credit still has practical effect for a Japanese parent under Japan's current dividend exclusion was not confirmed.
A Japanese company can exclude 95% of dividends received from a foreign company in which it has held at least 25% of the shares for a continuous six months or more, and the ownership percentage may be reduced by a tax treaty. Dividends that are deductible for tax in the payer's country are outside the exclusion.
Secondary source.
The BOI stated in November 2025 that existing tax exemptions and reductions under BOI promotion remain in place despite the global minimum tax, and that it is preparing a Qualified Refundable Tax Credit based on spending such as R&D, workforce development and productivity upgrades. Relevant to groups with consolidated revenue of EUR 750 million or more. The credit requires amendment of the National Competitiveness Enhancement for Targeted Industries Act; whether it is in force was not confirmed.
Thailand's Emergency Decree on the Top-up Tax B.E. 2567 (2024) applies global minimum tax rules to large multinational enterprise groups for accounting periods beginning on or after 1 January 2025. Large multinational enterprise groups; secondary legislation on restructurings, the undertaxed payments rule and the domestic top-up tax was approved in principle in December 2025.
The source does not state the EUR 750 million revenue threshold.
BOI corporate income tax exemptions depend on the activity group: 10 to 13 years for group A1+, 8 years for A1 and A2, 5 years for A3 and 3 years for A4, with no exemption listed for group B. Exemptions for groups A2 to A4 are capped at 100% of the project's investment (excluding land and working capital) as determined by the Board; A1+ and A1 have no cap. The group depends on the activity on the BOI list.
The Investment Promotion Act allows the BOI to grant exemption or reduction of import duty on machinery (sections 28 and 29), reduction of duty on raw or essential materials (section 30) and exemption on materials used to produce exports (section 36). Granted case by case in the promotion certificate.
BOI tax incentives include exemption from corporate income tax on the net profit and dividends derived from the promoted activity (sections 31, 31/1 and 34 of the Investment Promotion Act). Dividends are exempt only to the extent paid out of profits from the promoted activity during the exemption period; conditions are set in the promotion certificate.
Non-tax BOI incentives include permission to own land (section 27) and permission to bring in foreign skilled workers and experts to work in the promoted activity (sections 25 and 26). Section 37 also allows permission to take out or remit money abroad in foreign currency.
Foreigners are generally not permitted to own land in Thailand, with exceptions including land in industrial estates under the IEAT Act and BOI permission under Section 27 of the Investment Promotion Act. Exceptions apply only for the approved purpose.
Corrected on source check: the AI-written version cited the Land Code and said land leases are registrable for a maximum of 30 years, which the source does not state.
The minimum capital investment for a BOI-promoted project is THB 1 million, excluding the cost of land and working capital, unless the activity list states otherwise. Knowledge-based activities use a minimum annual salary expense instead.
Under Article 10(2) of the Thailand-Japan convention, source-state tax on dividends paid to a company owning at least 25% of the voting shares for six months is capped at 15% where the payer is engaged in an industrial undertaking and 20% in other cases. Industrial undertaking includes manufacturing, assembling and processing. Thailand's domestic withholding rate on dividends to foreign companies (10%) is lower than these caps, so the treaty does not reduce it.
A Thai private limited company can be formed by a minimum of two founders, who sign the memorandum of association before the company is registered. The memorandum is filed within 30 days of name approval and registration applied for within three months of the statutory meeting. Public limited companies follow separate legislation.
Corrected on source check: the AI-written version attributed the two-shareholder rule to a 2023 amendment of the Civil and Commercial Code, which the source does not mention. The same guide's structure table says at least three owners, so the figure should be confirmed with the Department of Business Development.
A reserved company name at the Department of Business Development is valid for 30 days, and a new company must apply for its corporate tax identification card from the Revenue Department within 60 days. Thai private limited company formation.
Under the Foreign Business Act, a foreign company's minimum capital may not be less than THB 2 million, or THB 3 million for businesses that need permission under the Act's lists. Ministerial regulations can set higher amounts; BOI-promoted companies and some activities follow different rules.
Under Article 21(2) of the Thailand-Japan convention, Japan credits Thai tax on Thai-source income against Japanese tax, and for dividends from a Thai company in which a Japanese company owns at least 25% of the shares the credit takes into account the Thai tax paid by the Thai company. The credit cannot exceed the Japanese tax on that income. How this indirect credit interacts with Japan's current foreign dividend exclusion should be confirmed with a Japanese adviser.
Thailand's withholding schedule shows treaty rates for Japan of 10% on dividends, 10% on interest paid to banks and financial institutions (0% for government-owned financial institutions, 15% otherwise) and 15% on royalties. The 10% dividend figure reflects the domestic rate. Interest and royalty rates apply under Articles 11 and 12, which could not yet be checked on the official text.
Secondary source for interest and royalties; the dividend article was read on the Revenue Department text.
The standard corporate income tax rate in Thailand is 20 percent of net profits (as at mid-2026). Thai companies and foreign companies carrying on business in Thailand. Reduced rates for small companies are listed as a gap.
The Revenue Department's Income Tax Guide for Foreign Company also gives 20 percent but is worded around 2015.
VAT is currently charged at 7 percent, a reduction by royal decree from the 10 percent rate set in Section 80 of the Revenue Code. Exports of goods are zero-rated; some supplies are exempt. Businesses with annual turnover above THB 1.8 million must register.
The 7 percent rate is confirmed by the BOI quick guide to starting a business in Thailand 2026 and the Revenue Department's VAT page; the end date of the current reduction was not confirmed.
A foreign company not carrying on business in Thailand is taxed by withholding at 10 percent on dividends and 15 percent on other income such as interest, royalties, capital gains, rents and professional fees, subject to treaty relief. Treaty rates and permanent establishment status can change the outcome.
Corrected on source check: the AI-written version listed service fees at 15 percent; the sources list professional fees. The same rates appear in section 2.1.8 of the BOI Business Guide to Thailand 2023.
The Thailand-Japan double taxation convention was signed on 7 April 1990 and applies to withholding taxes on amounts paid on or after 1 January 1991. Income taxes other than withholding apply for taxable years or accounting periods beginning on or after 1 January 1991.
Thai companies with income of at least THB 200 million that transact with related parties must file a transfer pricing disclosure form with their annual corporate income tax return, under section 71 bis of the Revenue Code. Related parties include companies where one holds at least 50% of the other's capital, directly or indirectly. Failure to file or incorrect reporting without justification carries a fine of up to THB 200,000.
Secondary source (law-firm article from 2020). The Revenue Department's own guidance could not yet be checked; confirm current thresholds and documentation rules.
Thai companies must have their annual financial statements audited by a certified auditor and file them with the commercial registrar at the Ministry of Commerce and with the Revenue Department. Private companies approve audited statements at a shareholders' meeting within four months of year-end; branches file within 150 days.
Corrected on source check: the AI-written version said statements are prepared under Thai Financial Reporting Standards and that small partnerships may use a tax auditor, which the source does not state. Narrowed after an independent re-check of the cited page.
The Japan-Thailand Economic Partnership Agreement entered into force in November 2007. Bilateral agreement covering trade in goods, customs procedures and other areas. The page does not cover rules of origin or certificates of origin.
The page gives the month and year only; the effective_from day is shown as the first of the month for indexing.
The Regional Comprehensive Economic Partnership entered into force on 1 January 2022 for Australia, Brunei Darussalam, Cambodia, China, Japan, Lao PDR, New Zealand, Singapore, Thailand and Viet Nam, and for the Republic of Korea on 1 February 2022. For the remaining signatories it enters into force 60 days after deposit of their instrument of ratification. Signed on 15 November 2020.
Singapore's trade ministry page (meti.gov.sg) lists the 15 participants as the ten ASEAN states plus Australia, China, Japan, the Republic of Korea and New Zealand; India is not among them.
Thailand has bilateral free trade agreements in force with Australia, New Zealand, Japan, Chile, Peru (early harvest) and India (early harvest). Agreements with Sri Lanka (signed February 2024), EFTA (signed January 2025) and Bhutan (signed April 2025) were not yet in force in October 2025.
Japan Pension Service lists social security agreements in force with 24 countries, and Thailand is not among them. Without an agreement, a Japanese employee sent to Thailand may face contributions in both countries; how Japanese enrolment continues for seconded staff must be checked.
The page lists agreements in force only; it does not show agreements signed or under negotiation.
Foreign nationals need an appropriate visa, usually a Non-Immigrant B visa, and a work permit before starting work in Thailand. The Long-Term Resident visa is a separate 10-year route for qualifying foreigners. BOI-promoted companies have streamlined routes.
Corrected on source check: the AI-written version also said some occupations are reserved for Thai nationals, which the source does not address.
BOI-promoted companies obtain approval of foreign expert positions from the BOI and process visas and work permits through the Single Window for Visa and Work Permit system, in use since 31 July 2018. Positions in manufacturing activities are approved for up to two years at a time; executive and management staff must generally be at least 27 years old with five years' relevant experience.
Undated presentation; some conditions are given in Thai text only.
Employers and employees each contribute 5 percent of wages to the Social Security Fund, subject to a monthly wage ceiling. The ceiling level is listed as a gap.
The page (last updated November 2018) gives 5 percent on the first THB 15,000 of monthly salary; the current ceiling was not confirmed.
Foreign exchange transactions in Thailand are supervised by the Bank of Thailand and must be carried out through licensed entities, mainly commercial banks with foreign exchange licences. Authorised money changers and money transfer agents are also licensed.
Corrected on source check: the AI-written version named the Exchange Control Act B.E. 2485 (1942), which the page does not name.
Non-residents can freely bring in and repatriate direct and portfolio investment funds and loan repayments, and dividends, interest and profits can be paid abroad up to the amount of the obligation. Authorised banks ask for supporting documents for transactions of USD 200,000 or more unless a Know Your Business process has been completed. Tax must be withheld before remittance.
Corrected on source check: the AI-written version said repatriation is permitted on presentation of supporting documents; the page requires documents only from USD 200,000.
Recipients of foreign currency of USD 1 million or more from abroad, including export proceeds, must bring it back to Thailand within 360 days of the export or transaction date. The funds must then be sold to an authorised bank or deposited in a foreign currency account within 360 days of receipt.
