::Withholding Tax Rates for Interest::

Withholding Tax Rates for Interest
under Thailand's DTAs
if the recipient of interest does not have a P.E. or fixed base in the source country
Country	Recipient of interest	Tax rate not exceeding	Notes
Country	Recipient of interest	Tax rate not exceeding	Notes
1. Germany	financial institution incl.	10	if the enterprise paying the interest
	insurance companies		engages in an industrial undertaking
	other persons	25	Note: for interest arising in Thailand,
			apply 15% tax rate in accordance with
			the Revenue Code
	government and financial	exempt
	institution wholly owned
	by the government
	other persons	exempt	interest on bonds issued by the
			government

2. France	other persons	3	interest paid on loans or credits
			granted for four years or more with the
			participation of a financing public
			institution to a statutory body or to an
			enterprise in relation to the sale of
			any equipment or to the survey, the
			installation or the supply of industrial,
			commercial or scientific premises and
			public works
			"Financing public institution" means in
			the case of France, COFACE and
			Natexis Bank and in the case of Thai-
			land means EXIM Bank, Government
			Savings Bank, Government Housing
			Bank, Bank for Agriculture & Agricultu-
			ral Cooperatives, Krung Thai Bank,
			Rattanasin Bank, Industrial Finance
			Corporation of Thailand
	any financial institution	10
	government	exempt

3. Singapore	any financial institution	10
	incl. insurance company
	other persons	25	Note: for interest arising in Thailand,
			apply 15% tax rate in accordance with
			the Revenue Code
	government	exempt

4. Netherlands	any financial institution	10
	incl. insurance company
	other persons	25	Note: for interest arising in Thailand,
			apply 15% tax rate in accordance with
			the Revenue Code

5. Italy	any financial institution	10	if the enterprise paying the interest
	incl. insurance company		engages in an industrial undertaking
	government and financial	exempt
	wholly owned by the
	the State
	other persons	exempt	interest on bonds issued by the
			government

6. Belgium	any financial institution	10
	incl. insurance company
	other persons	25	Note: for interest arising in Thailand,
			apply 15% tax rate in accordance with
			the Revenue Code
	government	exempt

7. Pakistan	any financial institution	10
	incl. insurance company
	other persons	25
	government	exempt

8. United Kingdom	bank or financial institu-	10
	tion incl. insurance
	company
	other persons	25
	government, central	exempt
	bank or any agency
	(other than agency with
	shared capital) wholly
	owned by the govern-
	ment

9. Malaysia	Malaysian financial insti-	10	interest arising in Thailand
	tution incl. insurance
	company
	other Malaysian persons	25	Note: for interest arising in Thailand,
			apply 15% tax rate in accordance with
			the Revenue Code
	Thai residents	15	interest arising in Malaysia
	government	exempt

10. Philippines	Philippines financial in-	10	interest arising in Thailand
	stitution incl. insurance
	company
	other Philippines persons	25	interest arising in Thailand
			Note: for interest arising in Thailand,
			apply 15% tax rate in accordance with
			the Revenue Code
	Thai residents	10	interest arising in the Philippines in
			respect of public issues of bonds,
			debentures or similar obligations
	Thai residents	15	interest arising in the Philippines
	government	exempt

11. Poland	any financial institution	10
	incl. insurance company
	government	exempt
			Note: for other persons, apply
			domestic tax rate (Thailand = 15%)

12. Canada	Canadian financial insti-	10	interest arising in Thailand
	tution incl. insurance
	company
	other Canadian persons	25	Note: for interest arising in Thailand,
			apply 15% tax rate in accordance with
			the Revenue Code
	Thai residents	15	interest arising in Canada
	government	exempt

13. Finland	any financial institution	10
	incl. insurance company
	other persons	25	Note: for interest arising in Thailand,
			apply 15% tax rate in accordance with
			the Revenue Code
	government	exempt

14. India	any financial institution	10
	incl. insurance company
	other persons	25	Note: for interest arising in Thailand,
			apply 15% tax rate in accordance with
			the Revenue Code
	government, local au-	exempt
	throity or central bank

15. Austria	any financial insitution	10
	incl. insurance company
	other persons	25	Note: for interest arising in Thailand,
			apply 15% tax rate in accordance with
			the Revenue Code
	government	exempt

16. China	any financial institution	10
	incl. insurance company
	government	exempt
			Note: for other persons, apply
			domestic tax rate (Thailand = 15%)

17. Sweden	any financial institution	10
	incl. insurance company
	any other company	25	Note: for interest arising in Thailand,
			apply 15% tax rate in accordance with
			the Revenue Code
	government or central	exempt
	bank
			Note: for other persons, apply
			doemstic tax rate (Thailand = 15%)

18. Hungary	any financial insitution	10
	incl. insurance company
	other persons	25	Note: for interest arising in Thailand,
			apply 15% tax rate in accordance with
			the Revenue Code
	government	exempt

19. Australia	any financial institution	10
	incl. insurance company
	other persons	25	Note: for interest arising in Thailand,
			apply 15% tax rate in accordance with
			the Revenue Code
	government or central	exempt	Interest derived from the investment
	bank		of official reserves by the government
			or by a bank performing central
			banking functions

20. Sri Lanka	any financial institution	10
	incl. insurance company
	other persons	25	Note: for interest arising in Thailand,
			apply 15% tax rate in accordance with
			the Revenue Code
	government	exempt

21. Japan	any financial institution	10
	incl. insurance company
	other persons	25	Note: for interest arising in Thailand,
			apply 15% tax rate in accordance with
			the Revenue Code
	government, central	exempt
	bank or financial insti-
	tution wholly owned by
	the government

22. Vietnam	any financial institution	10
	incl. insurance company
	other persons	15
	government	exempt

23. Czech Republic	any financial institution	10
	incl. insurance company
	government	exempt
			Note: for other persons, apply
			domestic tax rate (Thailand = 15%)

24. Switzerland	any financial institution	10
	incl. insurance company
	other persons	15
	other persons	exempt	if interest is paid in respect of a loan
			made or guaranteed or insured by
			the Bank of Thailand and EXIM Bank
			or under the Swiss provisions
			regulating the Export or Investment
			Gurantee

25. Israel	any financial institution	10
	incl. insurance company
	other persons	15
	government	exempt

26. South Africa	any financial institution	10
	incl. insurance company
	other companies	15
	government	exempt
			Note: for other persons, apply
			domestic tax rate (Thailand = 15%)

27. Romania	any financial institution	10
	incl. insurance company
	other companies	20	in the case of interest on credit sale
	other companies	25
	government	exempt
			Note: for other persons, apply
			domestic tax rate (Thailand = 15%)

28. United States of America	any financial institution	10
	incl. insurance company
	other persons	10	interest paid with respect to
			indebtedness arising as a
			consequence of a sale on credit of
			any equipment, merchandise or
			services
	other persons	15
	other persons	exempt	interest paid in respect of debt
			obligations guaranteed or insured by
			the government
	government	exempt

29. Laos	any financial institution	10
	incl. insurance company
	other persons	15
	government	exempt

30. Mauritius	any financial institution	10
	incl. insurance company
	other persons	15
	government, institution	exempt
	body or board wholly
	owned by the
	government

31. Luxembourg	any financial institution	10
	incl. insurance company
	other persons	15
	government	exempt

32. Bangladesh	any financial institution	10
	incl. insurance company
	other persons	15
	government	exempt

33. Nepal	any financial institution	10
	incl. insurance company
	other companies	15
	government	exempt
			Note: for other persons, apply
			domestic tax rate (Thailand = 15%)

34. Spain	any financial institution	10
	incl. insurance company
	other persons	15
	government	exempt

35. New Zealand	any financial institution	10
	incl. insurance company
	other persons	10	interest is paid with respect to
			indebtedness arising as a
			consequence of a sale on credit of
			any equipment, merchandise or services
	other persons	15
	government	exempt	interest derived from the investment
			of official reserves by the government,
			a bank performing central banking
			functions or EXIM Bank of Thailand

36. Denmark	financial institution incl.	10
	insurance companies
	other persons	15
	government	exempt
	other persons	exempt	interest paid in respect of a loan made
			by or guaranteed or insured by the
			government, the central bank, or any
			agency or instrumentality which is
			wholly owned or controlled by that
			government

37. Uzbekistan	any financial institution	10
	incl. insurance company
	other persons	15
	other persons	exempt	if the interest is paid in respect of
			loan made or guaranteed or insured, or
			in respect of any debt-claim or credit
			guranteed or insured on behalf of the
			the State by its authorised organ
	government	exempt

38. Cyprus	any financial institution	10
	incl. insurance company
	other persons	10	interest is paid in connection with the
			sale on credit of any industrial,
			commercial or scientific equipment,
			or of any merchandise
	other persons	15
	government	exempt

39. United Arab Emirates	any financial institution	10
	incl. insurance company
	other persons	15
	other persons	exempt	if the interest is paid in repsect of
			loans guaranteed or insured by the
			government
	government	exempt

40. Bulgaria	any financial insitution	10
	incl. insurance company
	other persons	15
	government	exempt

41. Armenia	Thai financial institution	10
	incl. insurance company
	Armenian institution	10
	having a license to carry
	on banking operations
	government, authority	exempt
	created therein, the
	Central Bank or the
	EXIM Bank of Thailand
			Note: for other persons, apply
			domestic tax rate (Thailand = 15%)

42. Indonesia	Thai residents	15	interest arising in Indonesia
	Indonesian financial in-	10	interest arising in Thailand
	stitution incl. insurance
	other Indonesian	25	Note: for interest arising in Thailand,
	residents		apply 15% tax rate in accordance with
			the Revenue Code
	government	exempt

financial institution incl.	10
	insurance companies
	other persons	15
	government	exempt
	other persons	exempt	interest paid in respect of a loan made
			by or guaranteed or insured by the
			government

44. Bahrain	any financial institution	10
	incl. insurance company
	other persons	15
	government	exempt

45. Oman	any financial institution	10
	incl. insurance company
	other persons	10	if the loan or debt-claim giving rise to
			the interest is guranteed by the
			government
	other persons	15
	government	exempt

46. Slovenia	any financial institution	10
	incl. insurance company
	other persons	15
	other persons	exempt	interest paid in respect of loan made
			or guranteed by the government
	government	exempt

47. Ukraine	a bank or any other	10
	financial institution incl.
	investment banks and
	savings banks and
	insurance companies
	other persons	15
	other persons	exempt	interest with respect to debt-cliams
			guaranteed, insured by the government
			the central bank or any other financial
			institution established and owned by
			the government to promote trade and
			investment
	government, the central	exempt
	bank or any other
	financial institution
	established and owned
	by the government to
	promote trade and
	investment

48. Turkey	any financial insitution	10
	incl. insurance company
	other persons	15
	government	exempt

49. Hong Kong	any financial institution	10
	or insurance company
	other persons	10	interest paid with respect to
			indebtedness arising as a
			consequence of a sale on credit of
			any equipment, merchandise or
			services
	other persons	15
	government	exempt

50. Seychelles	any financial institution	10
	other persons	15
	government	exempt

51. Kuwait	any financial institution	10
	other persons	15
	other persons	exempt	loans guaranteed or insured by the
			government
	government	exempt

52. Korea	any financial institution	10
	or insurance company
	other persons	10	interest paid with respect to
			indebtedness arising as a
			consequence of a sale on credit of
			any equipment, merchandise or
			services
	other persons	15
	government	exempt

53. Russian	any financial institution	10
	incl. insurance company
	government, central bank	exempt
	and EXIM bank
			Note: for other persons, apply domestic tax rate (Thailand = 15%)

54. Chile	any financial institution	10
	incl. insurance company
	other cases	15

55. Myanmar	Beneficial owner of	10
	the interest
	government	10

56. Chinese Taipei	any financial institution	10
	including insurance
	company
	other cases	15