Redomiciliation from offshore to Thailand

Redomiciliation from offshore to Thailand

Redomiciliation from offshore to Thailand

The business case for a re-domiciliation to the land of smile

The OECD is committed to the process which is euphemistically called “de-offshorization” and that means in real terms the complete destruction of the offshore corporate industry. The implementation of the global action plan on Base Erosion and Profit Shifting (BEPS) forced most offshore jurisdictions to dismantle their offshore tax legislation with respect to, above all,

  • economic substance and physical presence requirements,
  • transfer pricing rules and country-by-country reporting requirements,
  • abolishment of ring-fencing features, privileges for holding and foreign-source income companies
  • controlled foreign company rules and exit taxation,
  • limitation on interest deductibility
  • anti-tax avoidance provisions

Thailand is despite its corporate tax rate of generally 20% no low-tax jurisdiction and offers certain tax advantages, which should be inviting for the relocation of offshore investments to the land of smile.  

Offshore location independent legal services, tax advice, and transaction support 

PUGNATORIUS Ltd. advises and assists in the planning and implementation of a re-domiciliation to Thailand. A consultancy offer is available on request.

The law firm is the Bangkok-based specialist provider of transactional legal and tax advice on foreign investments in Thailand.  Flag theory for the nomad capitalist: Go where you’re treated best. The law firm has a long tradition and particular know-how to assist and advice offshore investors and cross-border transactions involving offshore jurisdictions on these seven offshore solutions:

  • Offshore legal and tax advice
  • Offshore company
  • Offshore bank account
  • Offshore investment and disinvestment
  • Offshore nominee services
  • Offshore FinTech
  • Offshore search and rescue services

The scope of professional services is further explained at

Disclaimer: A little knowledge is a dangerous thing. This low-resolution high-level outlook constitutes neither legal advice nor an attorney-client relationship. 

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