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HMRC internal manual

Double Taxation Relief Manual

From
HM Revenue & Customs
Updated
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Thailand: Dividends

Thai tax deducted from dividends paid by a Thai company at the agreement rate of 20 per cent (15 per cent if the company paying the dividend engages in an industrial undertaking - defined in Article 11(4) - and the dividend is paid to a United Kingdom resident company controlling at least 25 per cent of the voting power in the company paying the dividend) qualifies for credit as a direct tax (see DT950(c)). The reductions to above rates are not given where the dividends are effectively connected with (see DT214 fifth sub-paragraph) a permanent establishment which the recipient has in Thailand.

Where a dividend is paid to a United Kingdom resident company controlling, directly or indirectly, at least 25 per cent of the voting power in the Thai company paying the dividend, relief is also due under the agreement for the underlying tax (see DT950(d)) and Article 23(1)(b)). Where the United Kingdom company controls at least 10 per cent and not more than 25 per cent of the voting power in the Thai company, relief may be given unilaterally for the underlying tax.