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Regional Operating Headquarters (ROH) in Thailand

Regional Operating Headquarters status offers tax incentives for companies that manage, support, or provide services to affiliated companies abroad from Thailand. At Thai Visa Centre in Bangkok, we help ROH executives and specialists secure visas and work permits aligned with approved ROH activities.

ROH is a tax-incentive programme, not the same as a standard regional office registration, though structures may overlap. Revenue Department approval is required for tax benefits. See our regional office setup guide for DBD registration.

Authority
RD

Revenue Department grants ROH status for tax incentives. Separate from DBD regional office registration.

Service income
From abroad

ROH services must primarily serve foreign affiliates with income from abroad.

CIT on ROH income
Reduced

Historically reduced rate such as 10% on qualifying service fees. Confirm current rules.

Visa required
Yes

Foreign ROH executives need non-immigrant B visa and work permit.

What is ROH?

ROH is a status granted by the Revenue Department to qualifying companies that perform eligible services for foreign branches, subsidiaries, or associated enterprises with income primarily from abroad. ROH is popular with multinationals using Bangkok as an ASEAN hub.

Eligible service categories

  • Management, technical, or business support services
  • Financial management and advisory services for affiliates
  • International trading coordination between affiliates
  • International procurement services
  • Research and development
  • Marketing control and sales promotion for foreign markets

ROH tax benefits overview

Benefits depend on current Revenue Department rules and your approval letter. Confirm current rates with your tax advisor as incentives change.

BenefitTypical treatment
Corporate income tax on ROH service incomeReduced rate, historically around 10%, on qualifying service fees from abroad
Withholding taxExemptions or reductions on remittances in approved cases
Personal income taxExpatriate specialists may qualify for flat PIT rates on ROH employment income subject to conditions

ROH vs regional office

AspectROHRegional office
AuthorityRevenue Department (tax)DBD (registration)
FocusTax incentives for affiliate servicesRegistration category for coordination
IncomeService fees from foreign affiliatesLimited domestic trading
ApplicationROH licence application plus complianceDBD regional office registration

Application process

1

Structure review

Confirm entity can perform eligible ROH services to foreign affiliates.

2

Prepare application

Service descriptions, affiliate relationships, and financial projections.

3

Submit to Revenue Department

ROH application with supporting documents and transfer pricing files.

4

Approval and conditions

ROH certificate issued with reporting obligations and service scope limits.

5

Ongoing compliance

Annual ROH reports and transfer pricing documentation.

6

Visa and work permit

Non-immigrant B visa and work permit for foreign ROH executives and specialists.

Immigration for ROH staff

Foreign employees on ROH projects typically need a non-immigrant B visa from a Thai embassy and an employer-sponsored work permit. Job duties must reflect ROH service functions approved by the Revenue Department.

TVC handles visa and work-permit coordination. Your corporate lawyer and accountant prepare the ROH application.

Common mistakes: Mixing domestic revenue into ROH service income, insufficient transfer pricing files, and work permits describing roles outside approved ROH categories.

Common ROH mistakes

  • Assuming DBD regional office registration automatically grants ROH tax rates.
  • Insufficient transfer pricing documentation for affiliate service fees.
  • Domestic Thai revenue mixed into ROH service income incorrectly.
  • Work permits describing roles outside approved ROH service categories.
  • Missing annual ROH reporting deadlines with the Revenue Department.

Frequently asked questions

General answers for multinationals considering ROH status in Thailand. Confirm current requirements with the Revenue Department.

Q:Can a new Thai company apply for ROH?

A:Yes, if it meets capital, staffing, and service criteria from the start. Multinationals often incorporate specifically for ROH status in Bangkok.

Q:Does ROH replace BOI?

A:No. BOI and ROH address different incentives. Some projects may evaluate both but they are separate applications with different authorities.

Q:Are ROH service fees subject to VAT?

A:Export of services may have VAT treatment depending on place-of-supply rules. Confirm with your accountant and the Revenue Department.

Q:Can ROH employees use SMART Visa?

A:SMART Visa and ROH are separate programmes. Eligibility depends on role and employer category, not ROH status alone.

Q:What is ROH?

A:Regional Operating Headquarters is a Revenue Department status for companies providing eligible services to foreign affiliates from Thailand with income primarily from abroad.

Q:What capital is required for ROH?

A:Paid-up capital minimum historically around 10 million THB. Verify current threshold with the Revenue Department or your tax advisor.

Q:What immigration do ROH staff need?

A:Non-immigrant B visa from a Thai embassy and employer-sponsored work permit. Job duties must reflect approved ROH service functions.

Q:How is ROH different from a regional office?

A:ROH is a tax incentive programme from the Revenue Department. A DBD regional office is a registration category. Many groups operate both structures.

Official references