Passport number:Kok: 706/8401Date (s): October 6, 2006Re:: Corporate income tax and withholding income tax paying machine repair case and the international consultants.Legal code: Section 40 (2) of article 41, section 50 (1) and §§ 76 twin of revenue with an international complex tax haengonusanya Thai 7 with Japan.Any further discussions.: The company would know about the tax burden on business. As follows: 1. company business import & representation Broker to import industrial machinery, electronic equipment, chemicals and liquid lubricant on all kinds of electronic Engineer Service company engaged by K, which is a company founded in the Japan and does not have a permanent establishment in the country crossed the Thai.Fix the machine to the customer of the company by such machines, which are manufactured by the company K, which takes approximately 5 days of repair, the company will pay the money to repair the company K by means of money transfer to the account of Japan. Paying to repair these machines have been exempt from taxes according to International Convention, Thai country Japan. To leave the nest and prevent tax avoidance The revenue collected by In the section relating to income from taxes or not. 2. the company has hired a marketing consultant and sales planning, which is Japan, and live. In Japan, will arrive in the country at a time, twice a year, Thai 4-5 days, the company will pay. Advisory fee by way of bank transfer to the account of Japan on behalf of individuals each month, and the company has withheld tax from income paid in 15 percent of the money paid. The Advisory fee income tax exemption by the Convention with Thai international Japan or not.Diagnostic approach: 1. If K company is a company founded in the Japan. Send employees to repair machines in the Kingdom. It takes about 5 days, these cases can be considered Thai domestic affairs, consisting of K company. Are employed in operations in the country, Thai? In accordance with section 76 twin revenue property However, such income into a profitable business as an international haengonusanya 7 Thai country. Japan to leave the nest and prevent tax evasion of national revenue. In the case of income tax, it is not a permanent establishment if there are K company in Thailand by Thai haengonusanya 5 K, so the company is exempt from corporate income tax in Thailand tamonusanya Thai with the decree issued by the revenue code (vol. 18) 2505 (1962), and when the company paid. Repairs to the machine. Therefore, there are no duties, income tax must be deducted at any cost estimate. 2. If the company hired consultants, nationals of Japan for marketing consulting and planning which will be coming into the country each year, and 2 Thai in Thai country 4-5 days at a time without consulting Japan residents did not have as an employee of the company. Such income to estimate your income is based on section 40 (2) of revenue and is regarded as a personal service personal income tax in accordance with article 41 paragraph 1. National revenue because the compensation money that den was not the company. Income tax exempt according to article 14 of the International Convention on the Thai-Japan to leave to collect taxes and to prevent evasion of national revenue. In the section about the tax money. When the company pays compensation to withholding tax at a rate of 15.0 per cent according to section 50 (1) of revenue code.Number of cabinets: 69/34554clear-gif
การแปล กรุณารอสักครู่..
