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Investment Promotion Measure for Comprehensive Relocation Program

Investment Promotion Measure for Comprehensive Relocation Program

To encourage foreign investors in relocating integrated businesses, including manufacturing facilities, regional headquarters, and research and development centers, the Board of Investment hereby issues the following announcement:

1.

New investment in manufacturing projects to apply for investment promotion.

1.1 In the case of applicants applying for investment promotion, carrying out all activities under the same juristic person.

Conditions:

(1) The measure applies to applications submitted from January 2, 2024 until the last working day of 2024.

(2) Applications for investment promotion of manufacturing projects must be submitted together with applications for investment promotion of International Business Center (IBC) activities only, except activities that are not eligible for the incentives under specific policies as prescribed by the Office.

(3) The extension of the timeframe to accept the investment promotion and to submit documents for the issuance of promotion certificates is not allowed in all cases.

(4) The International Business Center (IBC) and/or R&D Center must begin to generate income and/or must provide services within one year from the date of investment promotion certificate issuance. If the applicants fail to comply with the condition within the specified period, the corporate income tax exemption will be withdrawn for three or five years, as the case may be.

(5) Applicants must undertake the substantial functions of regional headquarters and/or R&D centers as approved by the Board.

(6) In the case of investment in R&D centers, an operational plan must be presented which outlines the essence of being a research and development center.

Incentives

(1) Manufacturing projects applying for investment promotion together with an International Business Center (IBC) are eligible for an additional 3-year corporate income tax exemption on the net profit from investment in manufacturing activities. The tax incentive is granted in addition to the regular incentives based on activity criteria but must not exceed 8 years in total.

(2) Manufacturing projects applying for investment promotion together with an International Business Center (IBC) and an R&D center establishment are eligible for an additional 5-year corporate income tax exemption on the net profit from investment in manufacturing activities. The tax incentive is granted in addition to the regular incentives based on activity criteria but must not exceed 8 years in total.

(3) Non-tax incentives.

1.2 In the case that applicants for investment promotion carry out activities together with other juristic persons operating under affiliated enterprises

Conditions:

(1) The measure applies to applications submitted from January 2, 2024 until the last working day of 2024.

(2) Applications for investment promotion of manufacturing projects must be submitted together with applications for investment promotion of International Business Center (IBC) activities only, except activities that are not eligible for the incentives under specific policies as prescribed by the Office.

(3) The extension of the timeframe to accept the investment promotion and to submit documents for the issuance of promotion certificates is not allowed in all cases.

(4) International Business Center (IBC) must proceed as follows:

(4.1) It must be a new investment project applying for investment promotion in IBC. The investment must be made by the same juristic person or a new juristic person that is operated under the same affiliated enterprises as those promoted in manufacturing activities under this measure.

(4.2) The application for investment promotion in International Business Center (IBC) must be submitted according to the announcement of the Board of Investment No. 9/2565 dated December 8, 2022. The extension of the timeframe to import machinery and have a full operation start-up is not allowed in all cases. The request for full operation start-up must be made within one year from the date of issuance of the investment promotion certificate. If the projects are unable to proceed within the stated time limit, they will not be eligible for additional incentives for manufacturing projects carried out under the measure for comprehensive relocation program.

(4.3) Applicants must undertake the substantial functions of regional headquarters according to the conditions of IBC as approved by the Board.

(5) Manufacturing projects must proceed as follows:

(5.1) It must be a new investment project applying for investment promotion in activities in group A, except activities that are not eligible for the incentives under specific policies as prescribed by the Office.

(5.2) Applications for investment promotion of manufacturing projects must be submitted together with applications for investment promotion of International Business Center (IBC) activities only.

(5.3) If investing in an additional R&D Center, the following actions must be taken:

- The project must request to expand the scope of activities for the R&D Center. The R&D Center must begin to generate income and/or must provide services within one year from the date of issuance of the investment promotion certificate. If the projects are unable to proceed within the stated time limit, they will not be eligible for additional incentives for manufacturing projects carried out under the measure for comprehensive relocation program.

- In the case of investment in R&D centers, an operational plan must be presented which outlines the essence of being a research and development center.

(5.4) To receive additional incentives, an application must be submitted with a letter confirming an investment in IBC and/or evidence of the first generated income or the first provided service of the R&D Center. The application must be submitted during the period of corporate income tax exemption under regular measure.

Additional Incentives:

(1) Manufacturing projects applying for investment promotion together with an International Business Center (IBC) are eligible for an additional 3-year corporate income tax exemption on the net profit from investment in manufacturing activities. The tax incentive is granted in addition to the regular incentives based on activity criteria but must not exceed 8 years in total.

(2) Manufacturing projects applying for investment promotion together with an International Business Center (IBC) and an R&D center establishment are eligible for an additional 5-year corporate income tax exemption on the net profit from investment in manufacturing activities. The tax incentive is granted in addition to the regular incentives based on activity criteria but must not exceed 8 years in total.

2.

The existing Group A manufacturing projects that have been promoted and the corporate income tax exemption period has not been exceeded, except for activities under specific measures that are not eligible for incentives as prescribed by the Office.

2.1 In the case of applicants applying for investment promotion, carrying out all activities under the same juristic person.

Conditions:

(1) The applications must be submitted within the last working day of 2024.

(2) The project must request to expand the scope of activities for IBC whether the project has already generated income from operating IBC or not. At the date of application submission, the corporate income tax exemptions period and limit must not be exceeded.

(3) The International Business Center (IBC) and/or R&D Center must begin to generate income and/or must provide services within one year from the approval date for project amendments and before the exemption period under regular measure is exceeded. If the applicants fail to comply with the condition within the specified period, the corporate income tax exemption will be withdrawn for three or five years, as the case may be.

(4) Applicants must undertake the substantial functions of the regional headquarters and/or R&D centers as approved by the Board.

(5) In the case of investment in R&D centers, an operational plan must be presented which outlines the essence of being a research and development center.

Additional Incentives:

(1) Manufacturing projects applying for investment promotion together with an International Business Center (IBC) are eligible for an additional 3-year corporate income tax exemption on the net profit from investment in manufacturing activities. The tax incentive is granted in addition to the regular incentives based on activity criteria but must not exceed 8 years in total.

(2) Manufacturing projects applying for investment promotion together with an International Business Center (IBC) and an R&D center establishment are eligible for an additional 5-year corporate income tax exemption on the net profit from investment in manufacturing activities. The tax incentive is granted in addition to the regular incentives based on activity criteria but must not exceed 8 years in total.

2.2 In the case that applicants for investment promotion carry out activities together with other juristic persons operating under affiliated enterprises

Conditions:

(1) The applications for investment promotion for IBC must be submitted according to the announcement of the Office No. 9/2565, dated December 8, 2565, within the last working day of 2024

(2) International Business Center (IBC) must proceed as follows:

(2.1) It must be a new investment project applying for investment promotion in IBC. The investment must be made by the same juristic person or a new juristic person that is operated under the same affiliated enterprises as those promoted in manufacturing activities under this measure.

(2.2) The extension of the timeframe to accept the investment promotion, to submit documents for the issuance of promotion certificates, to import machinery and for a full operation start-up is not allowed in all cases. The request for full operation start-up must be made within one year from the date of issuance of the investment promotion certificate. If the projects are unable to proceed within the stated time limit, they will not be eligible for additional incentives for manufacturing projects carried out under the measure for comprehensive relocation program.

(2.3) Applicants must undertake the substantial functions of regional headquarters according to the conditions of IBC as approved by the Office.

(3) Manufacturing projects must proceed as follows:

(3.1) If investing in an additional R&D Center, the following actions must be taken:

- In order to expand the scope of activities for the R&D Center, the project amendment must be submitted together with an application for IBC project only, regardless of whether the original project has already generated income from manufacturing activities or not. At the date of application submission, the corporate income tax exemptions period and limit must not be exceeded.

- In the case of investment in R&D centers, an operational plan must be presented which outlines the essence of being a research and development center.

- The R&D Center must carry out activities that are the essence of being a research and development center as approved by the Office and must begin to generate income within one year from the date of the approval for the project amendment and the corporate income tax exemptions period under regular measure must not be exceeded.

(3.2) To receive additional incentives, an application must be submitted with a letter confirming an investment in IBC and/or evidence of the first generated income or the first provided service of the R&D Center. The application must be submitted during the period of corporate income tax exemption under regular measure.

Additional incentives:

(1) Manufacturing projects applying for investment promotion together with an International Business Center (IBC) are eligible for an additional 3-year corporate income tax exemption on the net profit from investment in manufacturing activities. The tax incentive is granted in addition to the regular incentives based on activity criteria but must not exceed 8 years in total.

(2) Manufacturing projects applying for investment promotion together with an International Business Center (IBC) and an R&D center establishment are eligible for an additional 5-year corporate income tax exemption on the net profit from investment in manufacturing activities. The tax incentive is granted in addition to the regular incentives based on activity criteria but must not exceed 8 years in total.

Read More :

Announcement of the Board of Investment No. 3/2567 : Investment Promotion Measure for Comprehensive Relocation Program

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