Emerging Markets Rates and Currencies Handbook

46 Citi | Emerging Markets Currencies Handbook 2021 Thailand NRQCs can enjoy the following benefits: • Eligible underlying is extended to include the projection of Baht revenue/expense or financial statements (balance sheet hedging) due to trade, in addition to actual service or investment activities of NRQCs in Thailand. • Underlying documents are not required to be submitted to FIs for checking. • NRs will no longer be subject to a day-end outstanding limit for NRBA. Citibank, N.A. Bangkok Branch 399 Interchange 21 Building Sukhumvit Road, Klongtoey Nua Wattana Bangkok 10110, Thailand FX Sales Contact: +66 2079 2222 Item Inter-Co Debt Offshore Bank Loans Offshore Local Borrowing Derivatives Equity W/H Tax 15% WHT • Under certain tax treaties typically 15%, with further reduction possible on country-by- country basis 15% WHT • Under certain tax treaties typically 10% rate applies to interest paid to a recipient that is a bank or financial institution (including an insurance company) No WHT 1% WHT on interest paid to all resident corporations other than banks or finance companies, except where interest arises from bonds or debentures N/A Dividend: • Resident corporation: 10% WHT (0% if recipient listed locally) • Non-treaty: 10% WHT • Treaty: 10% WHT Deductibility of interests Fully deductible N/A N/A Deductibility of FX losses Fully deductible N/A N/A Other taxes, duties Stamp duty on loan documents capped at THB 10,000 N/A N/A Comments N/A N/A N/A N/A N/A Note: Citigroup Inc. and any of its affiliates do not provide accounting, tax, or legal advice. Please seek advice from a relevant licensed advisor. Source: Relevant legislation, publicly available sources. Subsidiary Funding — Tax Consideration Tax Summary — Thailand