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SUWANVARA LAWFIRM
Suwanvara Law Firm Co., Ltd.
SUWANVARA LAWFIRM
SUWANVARA LAWFIRM
Suwanvara Law Firm Co., Ltd.
Foreign Investment Guide

Structuring Your Thai Subsidiary So Profit Can Move: Debt vs Equity, Where the IP Sits, and What the Bank Will Ask For

Cash gets trapped in Thai subsidiaries for structural reasons decided at incorporation, not banking ones. The debt-versus-equity choice you cannot cheaply reverse, where IP should be owned before the brand has value, the substance behind any charge to the Thai entity, and how these structures fail.

Suwanvara Law FirmCorporate & Tax Team10 min read

Cash is trapped for structural reasons, not banking ones

The call usually comes in the third year: the Thai subsidiary is profitable, the group wants the cash, and it will not move.

The cause is almost never the bank. It is a set of decisions taken at incorporation, by people optimising for speed of setup, that left the company with no clean channel for money to leave.

This guide covers those decisions. For withholding rates, treaty relief mechanics and the outbound-payment reporting requirements, see our foreign investor guide, which publishes them in full — this page does not restate them.

General information only, not advice on a specific matter. Rates, thresholds and documentary requirements change — confirm the current position for your structure.

1. Debt versus equity: decided once, at incorporation

The single most consequential funding decision, and the one most often made without thought.

Equity is permanent capital. It comes out through distribution, which depends on the company having distributable profit and completing its approval requirements. That can be years away for a business investing heavily up front.

A shareholder loan creates a repayment channel that can operate before there are distributable profits.

But it must be a real loan: documented before the money moves, on commercial terms, actually drawn, and actually serviced. Interest that is never charged, repayment dates that pass unremarked, and drawdowns with no facility agreement all point the same way — that this was equity with a different label.

What does not work is recharacterising after the fact. Calling something a loan in year three because you now need a repayment channel is the request we most often have to refuse.

Get the mix right at incorporation, informed by your actual funding profile: how long until profit, how much working capital, and how the group expects to be repaid.

2. Where the IP sits

Decide before the brand or technology has value. Moving it afterwards is a transaction with consequences, not an administrative step.

  • Outside Thailand, licensed in. The licence must exist, on defined terms, before revenue depends on it. It also has to be real: scope, quality control, and terms that a third party would recognise as a licence.
  • Inside the Thai company. Simpler, no licence chain — but the IP is then tied to an entity you may one day want to sell, restructure or wind down.

Either can be right. The wrong answer is discovering at diligence that ownership was never settled. Our trademark and IP ownership guide covers the mechanics.

3. Charges to the Thai entity: substance and benefit

Any charge from the group to the Thai company — management fees, cost recharges, technical services, brand or licence fees — is tested on substance and benefit. What was actually done, by whom, and what the Thai company received that it needed.

The failure is almost always evidential, not conceptual. The service was genuinely provided; nobody wrote down what it was.

Build the file as you go:

  • A written agreement, in place before the charges start
  • A scope of services describing what is actually delivered
  • Records of who performed the work — time, output, deliverables
  • A rational, documented basis for how the amount was calculated
  • Evidence of the benefit to the Thai company specifically, not to the group generally

Reconstructing this two years later is visibly reconstruction, and it reads that way to anyone examining it.

Royalties and brand licence fees are only as strong as the IP ownership behind them. A charge for the use of a mark that the charging entity does not clearly own is weak twice over.

4. What the bank and the Revenue Department will want

Evidence that the payment is what you say it is:

  1. The underlying agreement
  2. An invoice consistent with it
  3. Proof the service or supply actually happened
  4. Board or shareholder approvals where the payment type requires them
  5. Tax documentation appropriate to the payment type
  6. Residence or status evidence for the recipient where relief is claimed

Requirements vary by payment type and by bank. The delay is almost never the bank being difficult — it is a file assembled after the decision to pay rather than before.

5. How these structures fail

Nominee layers. The ownership on paper is not the ownership in fact. It holds until diligence, a bank review, a licence renewal or a falling-out — and then it does not. See our business classification guide for what is actually being sold when a formation agent offers you a Thai majority holder.

Undocumented recharges. Amounts moved between group companies for years with nothing supporting them. Individually small, collectively material, and impossible to defend retrospectively.

Cash swept before tax. Moving money to the parent before the Thai company's own obligations were settled. Converts a cash-flow convenience into a compliance problem attaching to the company and its directors.

No exit thinking. A structure built for operating and never for selling. Buyers discount for structural problems, and they find them.

6. Pre-incorporation checklist

  • Model the funding profile — how long to profit, how much working capital, how the group expects repayment
  • Set the debt–equity mix accordingly, and document the loan properly before money moves
  • Decide where IP sits, and put the licence or assignment in place before value accrues
  • Draft the intercompany services agreement before charging begins
  • Agree what evidence will be kept for each charge, and who keeps it
  • Confirm what documentation your bank requires for each payment type
  • Sanity-check the structure against a future sale — what would a buyer's lawyer ask?

Summary

DecisionIf you get it wrong
Debt vs equityNo repayment channel; cash trapped until distributable profit exists
Where IP sitsMoving it later is a taxable transaction, not an admin step
Service agreementsCharges cannot be supported when examined
Evidence disciplineReconstruction two years later reads as reconstruction
Nominee arrangementsStructure collapses at the moment of maximum consequence

Every one of these is cheap to decide before incorporation and expensive to fix in year three. Restructuring is a project; structuring is a meeting.

We advise foreign parents on Thai subsidiary structure, intercompany arrangements and the evidence discipline behind them. Initial consultation is free — call +66 92 254 2045 or send us the details. See also tax services and accounting and tax compliance.


This guide is published by Suwanvara Law Firm — a Khon Kaen law firm established in 1986. General information only, not legal advice on a specific matter.

Frequently asked questions

Why is our cash stuck when the company is profitable?+

Almost always for structural reasons decided at incorporation rather than anything the bank is doing. Common causes: funding was put in as equity when part of it should have been debt, so there is no repayment channel; charges to the Thai entity were never documented, so they cannot be supported now; or the intercompany arrangements exist on paper but not in substance, so the evidence for an outbound payment does not hold up. None of these are quick to fix once the company has been trading, which is why the structure deserves attention before the first baht arrives.

Should we fund the subsidiary with equity or a shareholder loan?+

Both are used and the mix matters more than the label. Equity is permanent capital and comes out through distribution, which depends on the company having distributable profit and meeting its approval requirements. A loan creates a repayment channel that can operate before there are distributable profits, but it has to be a real loan — properly documented, on commercial terms, and actually drawn and serviced. What does not work is calling something a loan after the fact because you now need it to be one. This is decided at incorporation and is expensive to change afterwards.

Can we charge the Thai company a management fee?+

You can charge for services genuinely provided, and the test is substance and benefit — what was actually done, by whom, and what the Thai company received that it needed. A recharge with no service description, no evidence of the work, and no explanation of how the amount was arrived at will not survive examination, and the failure is usually evidential rather than conceptual. Build the file as you go: scope of services, who performed them, time or output records, and a rational basis for the charge. Reconstructing it two years later is visibly reconstruction.

Where should our IP sit?+

Decide before the brand or technology has value, because moving it afterwards is a transaction with its own consequences rather than an administrative step. If IP is to sit outside Thailand and be licensed in, the licence must exist and be on defined terms before revenue depends on it. If it sits in the Thai company, understand that it is then tied to an entity you may one day want to sell, restructure or wind down. Either can be right; the wrong answer is discovering at diligence that ownership was never settled at all.

What will the bank and the Revenue Department want before releasing an outbound payment?+

Evidence that the payment is what you say it is. In practice: the underlying agreement, an invoice consistent with it, proof the service or supply actually happened, board or shareholder approvals where the payment type requires them, tax documentation appropriate to the payment, and residence or status evidence for the recipient where relief is being claimed. Requirements vary by payment type and by bank, and the delay is almost never the bank being difficult — it is a file that was assembled after the decision to pay rather than before.

What are the failure modes you see most often?+

Three. Nominee layers, where the ownership on paper is not the ownership in fact, which collapses at diligence or at a licence renewal. Undocumented recharges, where amounts moved between group companies for years with nothing supporting them. And cash swept to the parent before the Thai company's own tax and statutory obligations were settled, which converts a cash-flow convenience into a compliance problem attaching to the company and its directors.