Donating to a Thai school or sports body: is the deduction really doubled?

01Two decrees, read together

For a Chinese-invested factory in Thailand, donations are usually less a charity question than a local-relations one: equipment for the vocational school next door, sponsorship of a provincial sports event, a scholarship at a partner college. Whether any of that comes back through tax turns on two decrees published this month — and on one easily missed precondition, which is the route the money takes.

Both appear in volume 143, part 64 Kor of the Royal Gazette, and they are almost symmetrical. The difference is who may receive the donation.

• Decree No. 809 — educational institutions. Five categories: state educational institutions; schools under the Private School Act — but excluding non-formal schools (“rongrian nok rabop”) under that same Act; private higher education institutions under the Private Higher Education Institution Act; educational institutions established in Thailand under a treaty or agreement between the Thai government and a specialised agency of the United Nations; and high-potential foreign higher education institutions approved, with Cabinet consent, under Head of NCPO Order No. 29/2560 dated 26 May 2017.
• Decree No. 810 — sports bodies. Six categories: the Sports Authority of Thailand; provincial sports committees; provincial sports associations; sports associations using the words “of Thailand” in their name; the National Sports Development Fund established under the Sports Authority of Thailand Act; and the Department of Physical Education.

The timing test is identical in both: donations made between 1 January 2025 and 31 December 2027. Individuals and companies both qualify, and on the corporate side the donation may be in money or in property.

The first thing that goes wrong is the status of the recipient. Decree No. 809 excludes the whole class of non-formal schools under the Private School Act — institutions that are called schools in ordinary speech but fall outside the definition here. Confirming the recipient's legal character before donating is a great deal cheaper than discovering the problem afterwards.

02What is doubled is income, not tax — and the 10% denominators differ

The decrees exempt an amount of income equal to twice the donation. They do not halve or double a tax bill. More importantly, both put a 10% ceiling on that doubling, and the denominator is not the same for individuals and companies. This is the point most often miscalculated in practice.

• Individuals. The exempt amount is combined with other income exempted at twice the amount paid under other royal decrees, and the combined figure may not exceed 10% of assessable income after deducting expenses and allowances under section 47(1) to (6) of the Revenue Code.
• Companies and juristic partnerships. The exempt amount is combined with other double-deduction expenditure, and the combined figure may not exceed 10% of net profit before deducting expenditure for public charity or public benefit and expenditure for education or sports, as those terms are used in section 65 ter (3)(b) of the Revenue Code.

In both cases “combined” means exactly that: if the company is running other double-deduction reliefs in the same period, they share the allowance. Any modelling has to pool every double-deduction item in the period before testing it against the 10%. Otherwise it is easy to end up in the position where no single item breaches the cap but the total does.

03It has to go through e-Donation — a paper receipt will not do

The operative wording in both decrees is a donation “through the electronic donation system (e-Donation)”. That is not a filing preference; it sits in the granting provision itself, which means if the route is wrong, satisfying the remaining conditions does not help. The decrees define the system as one used to create and retain donation data in electronic form, as evidence supporting a claim to tax benefits under the Revenue Code.

In practice the bottleneck sits with the recipient, not the donor. Whether a donation can go through e-Donation depends on the receiving body holding a donation-recipient identification number and having registered as a system user. The Revenue Department's own guidance gives the self-check route: on rd.go.th, Juristic persons → Donation recipients → Check donation recipient information. A body that does not appear there has to obtain a number from its area revenue office first and then register.

So the order of operations is: check whether the recipient is in the system, then discuss the amount. Local schools and provincial sports bodies are not uniformly registered, and discovering that after the money has moved is how the doubling gets lost.

04Donating goods carries a second exemption — at the cost of the deduction

Alongside the income tax relief, each decree carries a provision for donations in kind: income from the transfer of property or the sale of goods, and instruments executed in connection with such a donation, are exempt from income tax, VAT, specific business tax and stamp duty. For a manufacturer donating equipment or materials, that layer is often worth more than the doubling itself.

The price is written into the same provision: the transferor may not then deduct the cost of that exempted property or those goods as an expense in computing income tax.

One point deserves to be read as written. This provision refers to a donation “to an educational institution” (respectively, a sports body) and does not repeat the words “through e-Donation”; it also delegates its criteria and conditions to a notification of the Director-General. Its scope therefore does not map exactly onto the doubling provision, and how it applies to a particular case should be settled against the notification in force rather than inferred from the doubling rule.

05No double-dipping — and one extra route in Decree No. 810

Both decrees close with an anti-duplication rule: a donation for which the income tax exemption has been taken may not also be claimed as a donation allowance under section 47(7) of the Revenue Code (individuals), or deducted as expenditure under section 65 ter (3)(b) (companies). The doubled relief and the ordinary single deduction are alternatives, not layers.

There is one arrangement found in Decree No. 810 and not in No. 809. Where an individual has taken the doubled exemption and part of the donation is left over because of the 10% ceiling, that remainder may still be excluded from assessable income — up to the amount of the remaining donation — under the criteria and conditions in clause 2(68) of Ministerial Regulation No. 126 (B.E. 2509). Sports donations, in other words, keep a single-value route open once the cap is reached; the education decree contains no equivalent provision.

06The window reaches back to 1 January 2025

Both decrees were published on 12 October 2026 and take effect the day after publication, yet they apply to donations from 1 January 2025. The explanatory notes set out why: the previous education measure was Royal Decree No. 768 (B.E. 2566) and the previous sports measure Royal Decree No. 772 (B.E. 2566), both of which applied only until 31 December 2024. This round picks up from 1 January 2025, leaving no gap.

For a company already operating in Thailand, that makes donations made during the 2025 accounting year worth a second look: whether the recipient falls inside the definition, whether the donation actually went through e-Donation at the time, and how much of the double-deduction allowance the period has left.

One caveat. Both decrees delegate their criteria, methods and conditions to a notification of the Director-General of the Revenue Department, and as at the retrieval date of this note no such notification accompanying these two decrees appears on the Department's new-legislation page. Qualifying amounts can be gathered now, but the timing of the claim and the supporting records should not be fixed before checking the notification then in force, and the figures need to be settled item by item against the company's actual profit for the period and its other reliefs.