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📊 Corporate Income Tax

Getting the P.N.D. 51 Half-Year Tax Estimate Right

Forecast the full-year profit on the basis of evidence, and manage the risk when the actual result differs from the estimate.

📋 Revenue Code, Section 67 bis
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The P.N.D. 51 is not simply the profit of the first six months multiplied by two. For companies in general, the net profit of the entire accounting period must be estimated from the information available on the date the return is prepared, and the half-year tax is then calculated under the statutory rules. If the actual result turns out to be much higher, the company must be able to explain that the original estimate was reasonable and supported by evidence, rather than a figure chosen simply to pay less tax.
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Contents
  1. Filing deadline and the principles of calculation
  2. The 25% underestimate threshold
  3. Reasonable cause requires contemporaneous evidence
  4. Forecasting methods better than multiplying by two
  5. What to do when the estimate turns out to be too low

Filing deadline and the principles of calculation

A company or juristic partnership that is subject to the requirement must file the P.N.D. 51 within 2 months from the last day of the first six months of the accounting period. If the accounting period follows the calendar year, the Revenue Department’s tax calendar for that year should be checked again, because public holidays and the entitlement to file online may make the final day different. An overview of corporate income tax for the whole year, from SME rates to the P.N.D. 50, is in our corporate income tax guide for SMEs (Thai).

  1. Estimate full-year revenue from actual figures, orders in hand, and the business assumptions for the second half of the year.
  2. Estimate tax-deductible expenses; do not use all accounting expenses without adjusting for Sections 65 bis and 65 ter.
  3. Calculate the net profit and the tax for the full year using the applicable rate, SME benefits, BOI benefits, and the net losses carried forward that can actually be used.
  4. Calculate the half-year tax in accordance with the return, and credit the tax paid when filing the P.N.D. 50.
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The 25% underestimate threshold

Section 67 ter of the Revenue Code uses the term “surcharge” (เงินเพิ่ม) for the case in which net profit is underestimated by more than 25% of the actual net profit without reasonable cause. The statutory rate is 20% of the tax underpaid, not 20% of the entire profit shortfall.

Example of applying the threshold: If the P.N.D. 50 shows an actual net profit of 10 million baht, but the P.N.D. 51 estimated 7 million baht, the shortfall is 3 million baht, or 30% of the actual profit. That exceeds the 25% threshold, so the next question is whether there was reasonable cause, before the tax underpaid is calculated at the company’s tax rate.
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Reasonable cause requires contemporaneous evidence

A second half of the year that is more profitable than expected may constitute reasonable cause, but there should be documents prepared at the time of the estimate, not reasons assembled afterwards when an audit begins. Examples of facts worth analyzing include large orders that arose later, the reversal of provisions, a sale of assets that was not planned on the filing date, or significant expenses that were canceled unexpectedly.

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Forecasting methods better than multiplying by two

ItemData to useRisks to adjust for
Recurring revenueContracts, average sales, renewal rates, and seasonalityCancellations, customer defaults, and year-end discounts
Project revenueWork in hand, delivery milestones, and revenue recognition conditionsDelays, variations, and acceptance of the work
Cost of salesActual gross margin, raw material prices, and purchase contractsExchange rates, waste, inventory, and abnormal costs
ExpensesBudget, employment contracts, and headcount plansNon-deductible expenses, capital expenditure, and related-party transactions
Special itemsPlans to sell assets, litigation, compensation, or restructuringUncertainty as to timing, amount, and tax consequences
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What to do when the estimate turns out to be too low

Prepare a new estimate immediately, check whether the return can still be amended and additional tax paid, and assess the surcharge according to the date on which payment will be made. The Revenue Department has guidelines for reducing the surcharge in some cases where the taxpayer corrects the return and pays voluntarily before receiving a warning or a summons, but the entitlement and the rate must be checked against the law and practice in force on the actual filing date.

Official sources (in Thai): Revenue Department — frequently asked questions on the P.N.D. 51, tax calendar, and instructions for the P.N.D. 51 form. Information verified on 27 June 2026 (B.E. 2569).

General legal information: This guide is general information on Thai tax law and is not legal advice on any particular case. This page is an English translation of the Thai original; the Thai text prevails.

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