Policy update
Nominee shareholder checks tighten, with look-through at registration
In short
From 2026 the checks on where a Thai shareholder's capital came from are being tightened at the company registration stage, and the tightening arrives in phases (bank statement requirements, online registration made compulsory, and similar steps). Regulators are looking through nominee shareholding arrangements markedly harder than before.
Using a nominee structureAll companies in Thailand
01What it means for you
If you are still using a nominee arrangement, or are considering one, your exposure is growing. Bringing the structure into compliance is better done early than late.
Does this reach you?
- Your company has a Thai shareholder holding shares for the foreign side
- The Thai shareholder cannot account for where their capital came from
- You have a capital increase or a change of registration coming up
If any of the above appliesThe tightening is a real exposure for you: the look-through check at the registration stage follows the money back to its source, and a change filing is the point where it is most likely to surface. Bringing the structure into compliance is better done early than late, and the first step is to have our advisers go through where you stand now.
Related
Sources
- Department of Business Development (DBD): phased measures, taking effect in stages from 2026; tracked on an ongoing basis by our advisers
Checked against the official texts by the CTAC Thailand advisory team. We track the gazettes of the BOI, the Revenue Department, the Department of Business Development and Thai Customs every week; when an official position changes, the affected pages are updated and dated.
This page is general information based on the rules in force at the date shown. Thai BOI categories, incentive conditions and foreign-investment rules change often. Before acting on any specific project, check the latest official announcement and have a formal opinion issued on your own facts.
Have our advisers check what this means for you
The same announcement does not land the same way on a company that already holds a certificate, one still applying, and an exporter.
中文版 · Chinese version