Key takeaways
- In principle, money can be brought into Thailand freely, but it must go through the banking system and you must keep the evidence, because this forms the basis for any future repatriation.
- Latest change: inbound funds of USD 200,000 or more per transaction must be supported by evidence of source, effective 8 October 2026, and money from the sale of Thai real estate to foreigners cannot use the KYB exemption.
- Thai tax law currently has no general thin capitalisation rule. The 3:1 D/E figure is a threshold in certain cases, such as BOI conditions or loan agreements.
Principle
Bringing foreign currency in to invest is governed by the Exchange Control Act 1942 and the related announcements of the Bank of Thailand (BOT). The principle is that money may come in, but it must pass through a bank and state its purpose. Money going out must be supported by documents. Bringing money in correctly from the start is therefore a condition for repatriating it later.
FX thresholds were adjusted several times in 2025–2026. The information in this article was reviewed as of the date shown on this page. Before making an actual transaction, confirm it with the receiving bank and your legal adviser.
Current thresholds to know
| Topic | Criteria | Effective |
|---|---|---|
| Evidence of source of inbound funds | From USD 200,000 per transaction, the bank must obtain documents showing the source. Customers who have passed KYB may be exempt for ordinary funds. | 8 Oct 2026 |
| Watchlist items | For example, money relating to Thai real estate sold to foreigners, and digital assets. From USD 200,000, evidence is required for every transaction. The KYB exemption cannot be used. | 8 Oct 2026 |
| Below USD 200,000 | Generally, state the purpose | 8 Oct 2026 |
| Foreign cash | Bringing in or taking out more than USD 20,000 or the equivalent must be declared to Customs | Threshold currently in use |
| Cash purchases by banks | Above USD 15,000 per person per day, the source must be shown, for example an import declaration | 8 Oct 2026 |
| NRBA/NRBS accounts | End-of-day balance of each type not exceeding THB 200 million per person | Under the latest BOT rules |
| Repatriating foreign income | Threshold raised from USD 1 million to USD 10 million per transaction | Announced 19 Jan 2026 |
Choosing the right channel for your purpose
1. Registered capital
Used when a foreign investor takes shares in a Thai company or increases its capital
- Transfer from abroad into the company's account through a commercial bank in Thailand
- State the purpose as investment in shares or share subscription
- Request a Foreign Exchange Transaction Form (FET) or a certificate from the bank
- Prepare evidence of payment for the shares as required by the registrar and the bank when registering with the Department of Business Development (DBD)
The advantage is that it provides clear evidence of the investment and is the basis for returning capital and receiving dividends. The point to watch is that a company with a Thai majority shareholding must involve genuine investment. Using Thai nationals to hold shares on a foreigner's behalf amounts to a nominee arrangement under the Foreign Business Act 1999.
2. Loans from foreign shareholders
Used when you want flexibility in repaying principal and interest without increasing capital
- Put the loan in a written agreement stating the interest, term and repayment schedule, and affix stamp duty as required by law
- Transfer into the company's account, stating the purpose as a loan from abroad
- Obtain documents from the receiving bank and keep copies with the counterparties' records
Interest paid to a foreign juristic person not carrying on business in Thailand is subject to 15% withholding tax (WHT). The rate may be reduced under a double taxation agreement. Interest should be at market level (arm's length).
On the 3:1 D/E ratio Many articles and handbooks state that a D/E ratio above 3:1 falls under thin capitalisation. However, according to the latest tax documents reviewed, Thai tax law currently has no thin capitalisation rule or general D/E ceiling. The figure usually comes from certain BOI conditions or bank covenants. Shareholder debt must still have genuine business substance and be supported by documents.
3. Booking deposits for condominium units from foreign buyers
The buyer transfers directly to the developer's or seller's account, stating the purpose as the purchase of a condominium unit, and keeps the evidence for use on the day of ownership transfer registration, in accordance with Section 19 bis of the Condominium Act 1979. The funds used must be foreign currency brought in, or arrive through channels prescribed by law.
- The bank issues an FET according to the transaction and its own minimum threshold, often cited as USD 50,000. Below that amount, a certificate or credit advice may be used.
- The document should show the foreign currency, the THB amount and the purpose.
- For amounts of USD 200,000 or more, always prepare evidence of source, because these fall under the watchlist.
- The sales team should tell the buyer from the booking date, not wait until transfer day.
4. FCD and NRBA accounts
A Foreign Currency Deposit (FCD) account is used to hold foreign currency in Thailand before converting to baht. A Non-Resident Baht Account (NRBA) is a baht account for persons resident outside Thailand. Outstanding balances are limited as shown in the table above. Do not plan to park large sums without checking the thresholds.
Convertible option
A convertible shareholder loan is a loan that converts into equity when conditions are met. It gives flexibility at the start, but the agreement and the registration of capital must be designed to comply with company law.
Supporting documents
- FET or bank documents showing the money brought in and the currency exchange
- Credit advice or SWIFT message showing the remitter, the recipient and the purpose
- Loan agreement signed by both parties, with stamp duty
- Share subscription agreement and shareholders' meeting resolution
- Company affidavit updated for the new capital
- Source of funds documents for KYC/AML
Taxes on repatriation
The table rates apply to foreign juristic persons not carrying on business in Thailand. A double taxation agreement may reduce or exempt the tax, subject to conditions.
| Cash flow | Withholding tax (WHT) | Notes |
|---|---|---|
| Bringing in capital | None | No tax on bringing in capital |
| Dividends | 10% | Check the treaty conditions |
| Interest | 15% | Often reduced to 10–15% under the treaty |
| Gains on the sale of shares | 15% | May be exempt under the treaty; check country by country |
Claiming treaty benefits requires a Tax Residency Certificate, and the recipient company must have genuine business substance. Beneficial ownership and the Principal Purpose Test mean that a structure without a business rationale cannot claim the benefits.
Additional privileges
| Topic | Key points | Points to check |
|---|---|---|
| BOI | May allow foreign shareholding in promoted businesses, corporate income tax (CIT) exemption by business category, and land ownership for the business under Section 27 of the Investment Promotion Act 1977 | General development for sale is usually not on the list. Check the business category and the duration of privileges with the BOI. |
| LTR Visa (Wealthy Global Citizen) | Invest at least USD 500,000 in Thailand in bonds, direct investment or real estate, hold total assets of at least USD 1 million, and meet the health insurance requirement or an alternative | Tax privileges differ by LTR category; check with the BOI |
| Treaty of Amity | US-nationality businesses can hold shares in Thai businesses more broadly | There are several exceptions, including land |
Managing currency risk
| Tools | How it works | Suitable for |
|---|---|---|
| Natural Hedge | Match the currency of receipts and payments | The project has receipts in foreign currency |
| Forward | Lock in the rate in advance; no upfront cost, but you give up any favourable movement | Cash flows with a known amount and date |
| FX Swap | Exchange two currencies today and exchange back at the agreed rate | Managing multiple currencies |
| FX Option | The right to buy or sell at a set rate, in return for a premium | Uncertain cash flows |
You do not need to hedge every item, but you should manage the large items that affect the funding plan. Anyone borrowing in a foreign currency while earning in baht should always include hedging costs in the cost of debt.
Common mistakes
- Bringing money in without going through a bank, or carrying cash above USD 20,000 without declaring it, which carries risks under customs law, exchange control rules and anti-money laundering law
- Using a nominee to hold shares on your behalf. Section 36 of the Foreign Business Act sets a penalty of imprisonment of up to 3 years, or a fine of THB 100,000–1,000,000, or both.
- Not requesting evidence from the day the money comes in, which makes it hard to prove the source retrospectively
- Stating a transfer purpose that does not match the actual use
- Assuming that shareholder debt is safe because it does not exceed 3:1, without checking the bank agreements or the business reality
Recommended steps
- Define the structure: equity, loan or a mix, and check the foreign business and BOI conditions
- Open accounts: a baht account and an FCD account with a commercial bank that offers FX services
- Prepare the source of funds documents before transferring
- Transfer the money: state the purpose clearly and request documents from the bank immediately
- Register and record: register the capital increase within 14 days of the date of the shareholders' resolution, under Section 1228 of the Civil and Commercial Code. A loan agreement does not need to be registered with the DBD, but it must be recorded in the accounts and the documents kept.
- Keep the documents for the whole life of the investment, because repatriation may occur after the legal retention period for accounting records has ended
This article provides general information and is not legal or tax advice. For actual transactions, consult a lawyer and a tax adviser.