Both Luxembourg and the Netherlands pay dividends to a Thai company at 0% when the conditions are met. Thailand then exempts them only if it holds 25% and the profits were taxed abroad at 15% or more, which a pass-through holding can put at risk. Thai residents pay tax when they bring foreign income home. A Thai parent with BOI incentives leans Dutch, and a new Dutch treaty signed in 2025 will add a PPT and cap Thai dividend tax at 10%.
Why Thai groups and families build a European base
Thai conglomerates have been buying European brands, hotels, food and energy businesses for years, and Thai families increasingly hold European property, funds and companies. Holding each asset directly from Bangkok means a different withholding tax, exit tax and bank conversation in every country. One holding in Luxembourg or the Netherlands puts the European assets under a single EU company that can own, finance and sell them.
Both countries pay dividends to a Thai company without withholding tax when the conditions are met, and both have treaties with Thailand. But the Thai side decides more than usual: how Thailand taxes foreign dividends, how it now taxes residents on money they bring home, and a brand-new Dutch treaty that changes the comparison.
Parent company or family
Thai company, family office or individuals; foreign investment largely unrestricted by the Bank of Thailand.
European holding
Owns, finances and sells the European assets.
Operating companies and assets
Brands, hotels, factories, property companies.
The Thai rules that shape the structure
- Foreign dividends to a Thai company. Exempt if the Thai company holds 25% or more for six months and the profits were taxed abroad at 15% or more (Royal Decree 442). Otherwise taxed at 20% with a credit for foreign tax.
- No CFC rules. Profits can stay in the European holding without Thai tax until they are paid out.
- Residents and remittances. Since 2024 Thai residents pay tax on foreign income from 2024 onwards whenever they bring it into Thailand, at rates up to 35%. A relief for money remitted in the same or next year is still a draft, not law. LTR visa holders in some categories are exempt.
- Money out is easy. Direct investment abroad is unlimited. Since December 2025 most outward transfers are allowed; receipts of USD 1 million or more must come back or be converted within 360 days.
- Large groups. Thailand applies the 15% global minimum tax from 2025 to groups with revenue of EUR 750 million or more.
For a Thai company the question is not whether Europe will tax the dividend. It is whether Thailand will, and that depends on how the European profits were taxed.
The 15% test and a pass-through holding
Thailand exempts foreign dividends only if they come from profits taxed at 15% or more. Luxembourg (23.87%) and the Netherlands (19% / 25.8%) clear that line on their headline rates. But a European holding whose own income is tax-free dividends from its subsidiaries pays almost no tax itself, and Thailand has not ruled on whether it looks at the holding's rate or at the profits underneath.
- Lower-risk designs. Operating subsidiaries taxed at normal rates, dividends passed up promptly, and a documented trail showing the underlying tax.
- Higher-risk designs. A holding of portfolio investments, or of subsidiaries in low-tax countries.
- Get it confirmed. For larger flows, ask for an advance ruling from the Thai Revenue Department before the first dividend.
Luxembourg, the old Dutch treaty and the new one
| Thailand–Luxembourg (1996) | Thailand–Netherlands (1975, in force) | Thailand–Netherlands (2025, signed) | |
|---|---|---|---|
| Dividends from Thailand | Up to 15%; Thai domestic rate 10% | Up to 15%; Thai domestic rate 10% | Up to 10% |
| Dividends to a Thai company | 0% under Luxembourg's exemption (20% Thai tax qualifies); treaty 5% at 25% | 0% under the Dutch exemption; treaty 5% at 25% | Up to 15%; Dutch exemption still applies |
| Interest | 10% (financial institutions) / 15% | 10% / 15% | 10% / 15% |
| Royalties | 15% | 5% (copyright) / 15% | 5% (copyright) / 10% |
| Gains on shares | Either country may tax share sales | Older wording | Residence country, except property-rich companies |
| Anti-abuse | Principal purpose test through the MLI | None in the treaty | Principal purpose test |
| Status | In force | In force until the new one applies | Signed 21 November 2025; date to be set |
Thailand is on neither the EU tax blacklist nor the FATF lists, and is not on the Dutch list of low-tax jurisdictions, so the Dutch 25.8% conditional withholding tax does not apply.
Plan your route
Five questions. The planner weighs the owner first, then the assets, stakes and substance.
Plan your Thai route into Europe
Five questions. You see the likely country, how Thailand taxes the money on the way home, and the traps.
What makes it hold up
Decisions in Europe
A board that meets in Luxembourg or the Netherlands and decides, not one that signs what Bangkok sends.
An office and books
A registered office, local accounts and records.
A business reason
Acquisitions, financing, European management or co-investors, in writing.
A clean money trail
Bank of Thailand forms, source of funds and the dividend chain documented for both tax offices.
Foreign dividends are exempt only from profits taxed at 15% or more.
Companies can wait; residents pay when the money comes home.
Luxembourg's 0% needs a fully taxed parent; the Dutch exemption does not.
Signed in 2025, it adds a PPT and lowers Thai dividend tax to 10%.