Estonian Company Run from Thailand: Tax Rules

Many people living in Thailand form or buy an Estonian private limited company (OÜ), often as e-residents, and run it from Thailand. The Thai Revenue Code ties a foreign company's tax to business carried on in Thailand: a company incorporated under foreign laws that carries on business in Thailand pays Thai tax on the net profits from that business, and a foreign company with an employee, an agent or a go-between in Thailand that receives income there is deemed to carry on business in Thailand. On the owner side, a Thai resident pays tax on income from abroad when it is brought into Thailand. And the Estonia–Thailand tax treaty counts a company resident in both countries as resident where it was incorporated. This guide sets out these rules with the official texts, and what we do on the Estonian side.

The guide is general information, not tax advice. How your company and you are taxed depends on the facts of your case; ask a Thai tax adviser before you form or buy the company. We read the Revenue Code in the English version published by the Thai Revenue Department on rd.go.th, and the Estonia–Thailand tax treaty in Riigi Teataja, on 22 October 2026. The Revenue Department's English text is a translation; the Thai text is the law.

In Estonia: an Estonian company is Estonian

A company established under Estonian law is resident in Estonia for tax purposes (Income Tax Act § 6). Its profit is taxed when it is distributed, not while it stays in the company — the guide how Estonia taxes company profit explains the rule. The company keeps its Estonian duties wherever its owners live: accounts, an annual report to the commercial register and, if its address is abroad, a contact person in Estonia.

In Thailand: the company side

Business carried on in Thailand. A company incorporated under Thai laws, or incorporated under foreign laws and carrying on business in Thailand, pays tax under the corporate income tax part of the Code; a foreign company carrying on business in other places including Thailand pays tax on the net profits from the business carried on in Thailand (Revenue Code, Section 66).
An employee, agent or go-between in Thailand. A company incorporated under foreign laws that has an employee, an agent or a go-between for carrying on business in Thailand, and as a result receives income or profits in Thailand, is deemed to carry on business in Thailand; that person is deemed its representative and must file the tax return and pay the tax on that income (Section 76 bis).
Income paid from Thailand. A foreign company not carrying on business in Thailand that receives certain income paid from or in Thailand — such as fees, interest, dividends or rent — is liable to tax, and the payer deducts it (Section 70).

An Estonian OÜ is a company incorporated under foreign laws for Thailand. If you live in Thailand and do the company's work from there, whether that is business carried on in Thailand is the question these sections raise. Your Thai tax adviser answers it with the facts of your case.

In Thailand: the owner side

Resident. A person staying in Thailand for a period or periods adding up to 180 days or more in a tax year is deemed a resident of Thailand (Revenue Code, Section 41, third paragraph).
Income from abroad. A resident of Thailand who derived assessable income from employment, from business carried on abroad or from property abroad pays tax on it upon bringing it into Thailand (Section 41, second paragraph).
Dividends. Dividends and shares of profits from a company are assessable income (Section 40(4)(b)).

How a dividend from the Estonian company is taxed in your hands in Thailand — and when it counts as brought into Thailand — is a question for your Thai tax adviser.

The Estonia–Thailand tax treaty

A company resident in both countries. A person other than an individual that is resident in both countries is resident only in the country under whose laws it was incorporated (Agreement signed in New York on 25 September 2012, Article 4(3)) — for an OÜ, that is Estonia.
Permanent establishment. A permanent establishment is a fixed place of business through which the business is wholly or partly carried on, such as a place of management, a branch or an office (Article 5).
Dividends. The country of the paying company may tax dividends at no more than 10 per cent of the gross amount when the recipient is resident in the other country (Article 10(2)).
Directors' fees. Fees for a member of the board of a company resident in the other country may be taxed in that country (Article 16).

The treaty settles residence; it does not stop Thailand from taxing the profits of a permanent establishment in Thailand. Whether the company has one is a question for your Thai tax adviser. We do not give that ruling.

What to decide before you form or buy the company

Where the business is done. Business carried on in Thailand, or through an employee, agent or go-between there, brings in Sections 66 and 76 bis.
Where you live. 180 days in Thailand in a tax year makes you a Thai resident under Section 41.
How you take money out. A dividend, a board fee and a salary fall under different articles of the treaty.

What we do on the Estonian side

online formation for an e-resident — €950 Registered address and contact person service for one year are included., or formation by power of attorney — €1,250;
a ready-made company bought remotely — €1,200 Registered address and contact person service for one year are included.;
accounting — from €150 / month and the annual report — from €450;
the registered address and contact person after the first 12 months — €350 / year.

Our accounting covers the Estonian company's Estonian obligations. Thai tax returns and Thai tax advice are not included. Owners in other countries: Estonian company run from abroad compares the rules side by side.

Prices exclude VAT. All communication takes place by email.

Ready to start? A new Estonian company — online for e-residents or by power of attorney; Thai tax advice is not included. Order.

Official sources

The laws this article names, by the name of their official text, as read on 9 October 2026. For the Estonian acts we read the English translation in Riigi Teataja; the legally binding text is the Estonian one.

Income Tax Act — Riigi Teataja, English translation

Sources are named in the text, without links. To see which of our services your company needs, open the Business Navigator.

Frequently asked questions

Is my Estonian company taxed in Thailand if I run it from Thailand?

It can be. Thailand taxes a company incorporated under foreign laws on the net profits from business carried on in Thailand, and a foreign company with an employee, an agent or a go-between in Thailand that receives income there is deemed to carry on business in Thailand (Revenue Code, Sections 66 and 76 bis). In Estonia the company stays resident because it was established under Estonian law (Income Tax Act § 6). Under the Estonia–Thailand tax treaty, a company resident in both countries is resident where it was incorporated — for an OÜ, Estonia (Article 4(3)); Thailand can still tax the profits of a permanent establishment there. A Thai resident pays tax on income from abroad when it is brought into Thailand (Section 41). Ask a Thai tax adviser before you form or buy the company; we handle the Estonian side.

Estonian company run from Thailand: what is taxed where