Certificate of Residence for Tax Purposes in Thailand

A Certificate of Residence for tax purposes (RO Certificate) is an official certificate issued by the tax authority of the country in which the applicant is a tax resident. The service on this page concerns certificates issued by the Thai Revenue Department to tax residents of Thailand, for use as evidence when claiming benefits under a double tax agreement with a treaty partner country.

Double tax agreements take effect in Thai law through Section 3 of the Royal Decree Issued under the Revenue Code Governing Exemption from Revenue Taxes (No. 18) B.E. 2505 (1962). In this context, a Certificate of Residence issued by the Thai Revenue Department serves as evidence of tax residence in Thailand, which a Thai tax resident may need in order to claim double tax agreement benefits in a country with which Thailand has concluded an agreement.

Tax residents of Thailand who may need to apply to the Thai Revenue Department for a Certificate of Residence fall into several categories, each with different tax residence conditions and supporting documents. A preliminary analysis of the conditions before applying is therefore an important step.

The documents required for a Certificate of Residence application differ according to the type of applicant, the country in which the certificate will be used, and the relevant agreement. We will help identify the documents required for your case on a case-by-case basis.

Note: The documents actually required depend on the type of applicant, the country in which the certificate will be used, the relevant agreement, and the requirements of the competent authority at the time of application. The current requirements should be checked before proceeding.

The legal consultant’s role in this process covers explaining the legal framework, analyzing the specific conditions of the case, and supporting the document preparation process so that it is carried out correctly and completely.

• Analyzing the tax residence conditions and feasibility. We assess the facts of the case to determine whether the applicant qualifies as a tax resident under the definitions in domestic law and the relevant agreement, and identify any risks that may arise.
• Reviewing and supporting the preparation of evidence. We review the existing documents, identify what is missing, and advise on how to obtain additional evidence that meets the requirements of the competent authority.
• Advising on the application of treaty benefits. Once the Certificate of Residence has been obtained, we analyze whether the other conditions of the relevant articles of the agreement are met and what the appropriate course of action is.
• Coordinating with our wider international tax advisory services. We connect the certificate application support with our advisory services on double tax agreements, transfer pricing, and international tax planning for the case as a whole.