Opening a holding company account in Thailand: ownership, dividends, checks

Dividends between Thai companies

A holding company account in Thailand receives dividends from Thai or foreign subsidiaries and funds the group, so it must be carefully documented. The bank examines the ownership chain, compliance with foreign ownership limits and the documentation of foreign currency flows. An unlisted Thai company holding at least 25 percent of another can have dividends fully exempt if the shares are held three months before and after the distribution.

An unlisted Thai company holding at least 25 percent of another, with no cross-shareholding, fully exempts dividends received if the shares are held three months before and three months after the distribution. Otherwise the exemption is partial.

Dividends from foreign subsidiaries

Dividends received from abroad are exempt when the Thai holding has held at least 25 percent of the voting rights for six months and the profits were taxed at a rate of at least 15 percent. The bank keeps records of the transfer.

10 percent withholding on dividends paid abroad

Dividends paid by a Thai company to a non-resident shareholder are in principle subject to 10 percent withholding tax. Tax treaties may reduce this rate, provided a certificate of tax residence is presented.

Thai nominees: an illegal practice

Using front Thai shareholders to get around the Foreign Business Act is an offence. Banks and the Department of Business Development examine the source of funds contributed by minority or majority Thai shareholders.

The bank's review of the ownership chain

At Bangkok Bank, opening a holding company account requires the chart up to the beneficial owners, the DBD-certified shareholder list and the source of capital. Planned intragroup flows must be described along with their currencies.

Repatriating dividends and exchange documentation

To pay dividends or return capital abroad, the holding shows the bank approved accounts and the distribution resolution. Evidence that the funds originally arrived in foreign currency eases the outflow under exchange controls.

Intragroup loans and the Thai related-party report

For a bank account for a Thai holding company, loans between the holding and related companies must be priced on market terms. Groups whose annual revenue exceeds the legal threshold must also file a related-party transactions disclosure report with the Thai Revenue Department each year.

Passive holding and CRS exchanges

For a Thai holding company bank account, a holding with no operating business may be classed as a passive non-financial entity. The Thai bank then identifies the persons controlling it and reports their data under the automatic exchange Thailand has carried out since 2023.

Incentive regimes for regional headquarters

Thailand has offered several successive tax regimes for regional headquarters and international business centres, subject to local spending and employment conditions. Eligibility should be checked with the Revenue Department or BOI before structuring the group.

French shareholder and income reporting

A shareholder who is French tax resident reports dividends from the Thai holding in France, with a tax credit provided by the bilateral treaty. Personal accounts in Thailand are listed on form 3916.

Steps to open a holding company account in Thailand

Before contacting a bank, the company must be registered and its structure settled: articles, capital, shareholder list certified by the Department of Business Development and appointment of directors. Also check that the capital split respects the foreign ownership limits that apply to the intended activity. A structure that is still moving delays the review of the file. A holding company account in Thailand is therefore prepared well before the first meeting.

The request usually goes through a meeting with a corporate relationship manager, sometimes with the signatories present. The bank asks about the subsidiaries, the source of capital, the dividends expected and the currencies involved. Answer in a structured way and back each point with a document, because the bank compares your statements with the papers provided.

After the checks, the bank opens the account in baht and, if needed, in foreign currency, then explains the available services. Timing depends on the complexity of the ownership chain and the number of countries involved; in practice allow several weeks and take nothing for granted. Send the capital only after written confirmation of the opening. A Thai holding company bank account is activated only after this step.

Documents to prepare to open a holding account in Thailand

Gather the registration certificate, the articles, the DBD-certified shareholder list, the resolution naming signatories and their identity documents. Add the chart up to the beneficial owners and the accounts of the main subsidiaries. These documents show the bank how the holding is owned and what it owns in return.

Document the source of capital and of the funds contributed by each shareholder: contribution agreement, bank statements, shareholders' decision or sale evidence. If Thai minority or majority shareholders appear in the structure, the bank also examines the source of their funds. Finally, prepare a simple note describing the planned flows and their currencies. The bank expects the holding to prove its own coherence, from capital to flows.

Documents from abroad may need translation and, depending on the bank, legalisation. Ask for the written list with the validity period of each item. Keep the tax residence certificates of foreign shareholders, because they are used to apply tax treaties to the withholding on dividends paid abroad at future distributions. A well-documented bank account for a Thai holding company opens more smoothly.

Questions to ask before opening a bank account for a Thai holding company

Ask the bank which structures it accepts: some refuse complex ownership chains or holdings with no activity in Thailand. State the nationality of the shareholders and the capital split at the first meeting, to avoid a late refusal. Also ask whether a minimum deposit or a visit by the signatories is required before the account is activated.

Then ask about practical matters: foreign currency accounts, international transfers, account fees, exchange cost, dual-signature rules and online banking for businesses. Have the bank explain how it handles dividend outflows and the repayment of capital, and which documents it requires to apply exchange controls to each operation. Note each answer received.

Finally, ask how the bank monitors the file: frequency of updates, documents to supply when a shareholder or director changes, treatment of a change of activity. Compare at least two institutions before choosing the one that suits both your structure and your flows. Also check which update requests will come back every year.

Common mistakes and checks before choosing the bank

The gravest mistake is using front Thai shareholders: the practice is an offence, and both the bank and the authorities examine the source of funds of every shareholder. Another error is capital that is announced but never paid up, or an undocumented foreign currency contribution, which later complicates the repatriation of dividends.

Do not neglect taxation. The withholding on dividends paid abroad, the exemption conditions between companies, intragroup loans on market terms and any incentive regimes must be checked with a local adviser. A French tax resident shareholder reports dividends in France, along with personal accounts opened in Thailand.

Before transferring funds, check that the bank is authorised by the local regulator and be wary of intermediaries promising a guaranteed opening: nobody can commit to that in the institution's place. The information on this page is general; for your structure, have each point confirmed by a lawyer or tax specialist in Thailand. A holding account in Thailand is a management tool, not a tax guarantee.