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Thailand<br />

2.8 K<strong>ey</strong> <strong>tax</strong> <strong>policy</strong> changes in 2014<br />

• <br />

<strong>tax</strong> bill in November. Under this bill, the <strong>tax</strong> will be 10%<br />

on estates valued at over THB50 million (approximately<br />

US$1.5 million) and 5% on gifts transferred to heirs be<strong>for</strong>e<br />

the principal’s death. Provided it passes deliberation by the<br />

<br />

second half of <strong>2015</strong>.<br />

• A draft land and buildings <strong>tax</strong> is being prepared, although it is<br />

unlikely to be effective be<strong>for</strong>e 2016.<br />

• The Cabinet has approved a law to reduce <strong>tax</strong> evasion by<br />

independent professionals, partnerships and bodies of<br />

persons, which plugs loopholes whereby members of bodies<br />

of persons were not required to include their share of the<br />

body’s income in their personal income <strong>tax</strong> reporting and<br />

partners could deduct certain expenses as a lump sum, even<br />

if no actual expenses were incurred. The changes may be<br />

effective <strong>for</strong> the <strong>2015</strong> <strong>tax</strong> year.<br />

2.9 Country position on OECD Base Erosion<br />

and Prot Shifting (BEPS) Action Plan<br />

• <br />

or action plans haves no impact on the Thai <strong>tax</strong> authority’s<br />

interpretations and positions.<br />

• The Thai <strong>tax</strong> authority generally refers to domestic <strong>tax</strong> laws<br />

and relevant <strong>tax</strong> treaties to determine Thai <strong>tax</strong> treatment<br />

of cross-border transactions. Where the <strong>tax</strong> authority<br />

believes a multinational company may have attempted to<br />

<br />

is likely to question or challenge the business purpose and<br />

<br />

a dispute or trigger a <strong>tax</strong> audit.<br />

• There is one newly signed <strong>tax</strong> treaty with Estonia, which<br />

became effective on 1 January 2014.<br />

• <br />

promoting investment in Thailand and grants <strong>tax</strong> and<br />

<br />

<br />

outbound as well as inbound investment, and it will propose<br />

incentives <strong>for</strong> inbound investments that are more industrybased<br />

than location-based, in order to promote new regional<br />

industry clusters. As a result, the number of activities eligible<br />

<strong>for</strong> promotion will be reduced by about 50. Priority activities<br />

will be given the maximum eight-year CIT exemption, and<br />

these include biotechnology, research and development,<br />

production of electricity or steam power from refuse-derived<br />

<br />

design and embedded software development. For outbound<br />

<br />

and in<strong>for</strong>ming companies making outbound investments.<br />

• <br />

Thailand as an international trading center <strong>for</strong> the<br />

<br />

the process of drafting <strong>tax</strong> incentives <strong>for</strong> International<br />

Headquarters (IHQ), while the IHQ has already replaced<br />

<br />

eligible activity list.<br />

182 | The <strong>outlook</strong> <strong>for</strong> <strong>global</strong> <strong>tax</strong> <strong>policy</strong> in <strong>2015</strong>

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