Thailand BOI incentives: investing in Thailand with BOI promotion
TGS Innovised — De Voorwaarts
Updated: 30 September 2026
- With BOI promotion, a project in Thailand can be exempt from Thai corporate income tax (normally 20%) for up to 13 years.
- For most promoted activities, foreign investors may hold 100% of the shares and own land.
- A BOI application typically takes three to five months from preparation to certificate.
- Holding the Thai company through a Dutch holding company? Consider the participation exemption, transfer pricing and Pillar Two.
Thailand has attracted foreign manufacturers for many years. A key reason is the Thailand Board of Investment (BOI). With a BOI promotion certificate, a company can be exempt from Thai corporate income tax for many years and import machinery free of import duty. As a foreign owner, you can also hold 100% of the shares and own land. These benefits come with conditions and obligations. For a Dutch shareholder, the Dutch tax position matters as well. This article sets out the key points of investing in Thailand with BOI promotion.
What is the BOI in Thailand?
The Board of Investment is the Thai government agency that promotes investment. The BOI grants incentives per activity, not per company. A company applies for promotion for a specific project, such as the manufacture of automotive parts, electronics or food products. Once approved, it receives a promotion certificate setting out the incentives and conditions for that project.
Tax incentives under BOI promotion
The BOI classifies activities into groups. The more important the activity is for Thailand, the greater the incentive:
| Group | Type of activity | Corporate income tax exemption |
|---|---|---|
| A1+ | Advanced technology and R&D | 10–13 years, no cap |
| A1 | Knowledge-based activities | 8 years, no cap |
| A2 | Infrastructure and high technology | 8 years, capped at the investment amount |
| A3 | Technology with limited presence in Thailand | 5 years, capped at the investment amount |
| A4 | Less advanced technology that adds value | 3 years, capped at the investment amount |
| B | Supporting activities | No basic exemption (merit-based only); import and other incentives apply |
The standard Thai corporate income tax rate is 20%.
Additional incentives through merits
A company can obtain additional years of exemption, up to a maximum of 13 years in total. It can do so by, for example, investing in research and development, staff training or the development of local suppliers, or by locating in one of the 20 provinces with the lowest per capita income.
Other tax incentives
- Exemption from import duty on machinery.
- Exemption from import duty on raw materials used for export products.
- Dividends from exempt profits are exempt from Thai tax for the shareholder, including the standard 10% withholding tax, provided they are paid during the exemption period or within six months after it ends.
- In some cases, a 50% rate reduction after the exemption ends, or additional deductions for costs such as transport, electricity and infrastructure.
Non-tax incentives
For foreign investors, these benefits are often at least as important:
- 100% foreign ownership. Thailand’s Foreign Business Act normally limits foreign ownership to 49% in many sectors. As a rule, this limit does not apply to the promoted activity.
- Land ownership. A BOI company may own land for the promoted activity, even if it is foreign-owned.
- Foreign staff. Visas and work permits for foreign experts are arranged quickly through a one-stop service, without the usual capital and Thai employee requirements. See our article “Posting an employee to a Thai BOI factory: local employment or secondment?”.
- Repatriation of profits. Profits and capital may be remitted abroad in foreign currency.
Temporary BOI measures for 2026–2027
For applications in 2026 and 2027, the BOI has introduced additional measures, aimed mainly at large investments:
- Expansion of existing production for companies with at least three BOI projects (together at least THB 10 billion) and an expansion of at least THB 500 million.
- Relocation of an entire business to Thailand, where manufacturing is combined with a regional headquarters or R&D.
- Large investments of THB 2 billion or more made within twelve months. This measure already ends on 31 December 2026.
- Measures for the automotive industry, including for automation and joint ventures with Thai partners.
Conditions for BOI promotion
- Minimum investment of THB 1 million, excluding land and working capital. Some activities require a higher amount (see the BOI project criteria).
- Activity-specific conditions, for example on the technology used, the age of machinery, value added and environmental requirements.
- Implementation as approved. Location, scale and technology must match the approval.
- Foreign employees must earn a minimum salary depending on their position. This applies to new certificates issued from 1 October 2025 and to existing projects from 1 January 2026. Manufacturers with 100 or more employees must have at least 70% Thai staff.
The BOI application process in 7 steps
- Check in advance whether the activity is on the BOI list and which group it falls into.
- Submit the application online with a project plan covering investment, production, staff, technology and location.
- Present the project to the BOI.
- Await the decision. The timeline depends on the size of the project: approximately 40 working days up to THB 200 million, 60 working days up to THB 2 billion and 90 working days above that.
- Accept the promotion in writing, usually within one month.
- Incorporate the Thai company, if it does not yet exist, and receive the certificate.
- Start the activity and report on progress annually.
Allow three to five months from preparation to certificate. The Thai government describes the procedure in its guide for foreign investors.
Obligations after BOI approval
BOI status is not a one-off approval. The company must report annually and continue to meet the conditions.
A BOI company held through a Dutch holding company
Do you hold the Thai company through a Dutch holding company? Then the following points are relevant:
- Dividends to the Netherlands. An active Thai manufacturing company generally qualifies for the Dutch participation exemption (in Dutch). The dividend is then tax-exempt at the level of the Dutch holding company, even if the Thai profit was untaxed because of the BOI exemption.
- Transfer pricing. Does the Dutch business supply goods, services, know-how or staff to the Thai company? Then the prices must be at arm’s length. Because of the low Thai tax burden, tax authorities scrutinise this closely. See our article “Transfer pricing for SMEs”.
- Pillar Two. Is the Thai company part of a group with revenue of € 750 million or more? Then a BOI exemption may trigger a top-up tax of up to 15%. Thailand introduced the global minimum tax with effect from 1 January 2025. The BOI offers these groups, subject to conditions, a reduced rate of 10% instead of the exemption. Nothing changes for smaller groups. See also our article “Pillar Two in the financial statements”.
Our tip
Do not treat the BOI application as a stand-alone Thai formality. The choice of activity, merits and location determines how many years of exemption you receive. The structure from the Netherlands determines whether that benefit actually reaches you as a shareholder. Have both sides reviewed together in advance.
Frequently asked questions about Thailand BOI incentives
What is BOI promotion in Thailand?
How many years of tax exemption does the BOI grant?
How long does a BOI application take?
Advice on investing in Thailand?
Contact our international tax specialists. Together with our partners in Thailand, we assess whether your project qualifies for BOI promotion and how best to structure it from the Netherlands.