Spending on an e-Tax Invoice system: is there a second deduction?

01What the relief actually gives you

The Revenue Department has spent several years pushing e-Tax Invoices and e-Receipts. On the company side that means putting in a system, buying certificates, renting storage and paying service providers. Royal Decree No. 808 gives part of that money back through corporate income tax. It was published in the Royal Gazette on 12 October 2026, but it applies from 1 January 2026 — so money already spent this year is very likely in scope.

It is worth being precise about the structure, because what is exempt is not the tax. The decree exempts an amount of income equal to the qualifying spending, set at 100% of the amount actually paid. The spending itself is still treated the ordinary way — expensed under the normal rules, or depreciated under section 65 bis (2) of the Revenue Code for assets. The two run alongside each other, and it is the combination that carries the value.

When and how you claim it is not in the decree. Sections 4, 5 and 7 all close with the same sentence: in accordance with the criteria, methods and conditions prescribed by notification of the Director-General of the Revenue Department. The filing-level specifics — which accounting period the 100% is claimed in, what has to be attached, whether assets are claimed once or spread — follow that notification. You can gather the qualifying amounts now, but do not fix the timing of the claim before checking the notification in force.

02Three kinds of spending, in three separate sections

The decree splits the relief across three sections, and they do not all apply to the same people.

• Section 4 — the e-document side. Investment in systems for preparing or receiving electronic data, or purchases of computer programs, electronic certificate storage devices, computers and equipment used with them — where the purpose is to prepare, deliver, receive or store e-Tax Invoices or e-Receipts. It does not cover repairs that restore an asset to its original condition within the meaning of section 65 ter (5).
• Section 5 — the tax remittance side. Investment in a tax remittance system, or the related hardware and software, used to remit withholding tax, income tax or VAT under section 3 quindecim of the Revenue Code. This one applies to juristic persons carrying that remittance duty, and to tax remittance service providers.
• Section 7 — service fees. Three kinds, paid in the same window: (1) fees paid to providers who prepare or deliver electronic data, electronic certificate fees, and electronic data storage (cloud storage) fees, for preparing, delivering or storing e-Tax Invoices or e-Receipts; (2) the equivalent fees paid to tax remittance providers, for remitting withholding tax, income tax or VAT; and (3) information system assessment fees and related charges paid to the Electronic Transactions Development Agency (ETDA) in order to qualify as a provider preparing or delivering electronic data.

All three use the same timing test: actually paid between 1 January 2026 and 31 December 2027. It turns on the payment, not on the date of the contract or the invoice.

03Six conditions the assets must meet together

Section 6 sets six conditions for assets under sections 4 and 5. They apply cumulatively — miss one and the whole claim falls away.

• Never previously used — second-hand equipment is out.
• Depreciable under section 65 bis (2), and acquired and in a condition fit for its intended use by 31 December 2027.
• Located in Thailand.
• Used for no fewer than three consecutive accounting periods, counting from the first accounting period in which it was acquired and ready for use.
• Not an asset already receiving a related tax benefit under another royal decree issued under the Revenue Code, whether in whole or in part.
• Not an asset used in a business that enjoys a corporate income tax exemption under the Investment Promotion Act (BOI), the National Competitiveness Enhancement Act for Targeted Industries, or the EEC Act, whether in whole or in part.

That last condition is a hard limit for BOI companies. Spending on an e-Tax Invoice system used on a BOI-exempt line of business cannot also take this relief, and the text says “whether in whole or in part” — so a single machine that is only partly used on the exempt line puts the whole claim at risk. Companies running both BOI and non-BOI operations need to assign the assets to a line of business first, then decide which part goes down this route. Doing that split at filing time is usually too late to assemble the supporting records. Read it together with the three-period condition: if the system is due for replacement within three years, work out what an early disposal does to a claim already made.

04Two kinds of business cannot use section 4

The second paragraph of section 4 carves out two groups: providers who prepare or deliver electronic data themselves, and developers writing software to sell or to provide as a service to others. The relief is for companies that use these systems, not for companies that build them.

Note that section 7(3) runs the other way — the ETDA assessment fee is deductible precisely because the purpose is to become such a provider. The two are consistent: one covers investment for your own use, the other covers the compliance cost of qualifying as a provider.

05How this round joins up with the last one

The explanatory note at the end of the decree records that the previous measure of this kind was Royal Decree No. 766 (B.E. 2566), which applied until 31 December 2025. This round picks up from 1 January 2026 and runs to 31 December 2027, with no gap in between.

That makes qualifying spending already incurred during 2026 worth revisiting — particularly systems that went live in the first half of the year, and annual service and storage fees already paid. The treatment, the supporting records and the timing of the claim need to be settled item by item against the company's actual lines of business and the Director-General notification in force.