Shared services and treasury centres come off the licence requirement
The Ministerial Regulation Prescribing Service Businesses Not Requiring a Licence for Foreign Business Operation (No. 5) B.E. 2569 was published in the Royal Gazette on 28 August 2026 (Vol. 143, Part 51 Kor, pp. 31-34). It adds items (13) to (18) to the 2013 regulation of the same name. Four of them bear directly on Chinese-invested groups in Thailand: administrative, human resources and information technology management services between affiliated juristic persons; treasury centres under the exchange control law; debt guarantees between affiliated juristic persons within Thailand only; and the leasing of part of a premises to install financial service terminals and vending machines for a company's own staff. The other two are telecommunications services under a Type One telecommunications licence, held by operators with no network of their own, and petroleum drilling services contracted directly with a concessionaire, a production sharing contractor or a service contractor. The same regulation also reworks the securities lending, repurchase and futures entries.
01What it means for you
Two things are easy to get wrong. First, there is more than one affiliation threshold. The shared services item runs on one entity holding at least 25 per cent of the other's capital; the domestic guarantee item runs on 50 per cent. Both also treat entities as affiliated where more than half the shareholders or partners overlap, or where more than half the directors or partners holding management authority overlap. One shareholding table will not settle every item at once. Second, what falls away is the licence application, not the restriction itself. The exemption sits in the carve-out that List Three already carries, so where the conditions are not met the original licensing requirement returns. The regulation carries no commencement clause of its own. Which date applies to you, and whether your group structure qualifies, needs the advisory team to work through the published text and your registration documents item by item.
- Your Thai company provides administrative, HR or IT management services to other companies in the group
- You run a treasury centre in Thailand, or are considering one
- Affiliated companies guarantee each other's debts inside Thailand
- You once applied for a foreign business licence specifically for one of these activities
These activities now sit on the no-licence list, but whether you can rely on it turns on how closely the two entities are affiliated: 25 per cent for shared services, 50 per cent for domestic guarantees, or a majority overlap of shareholders or of directors holding management authority. If you already hold a licence, it is worth checking once more whether its scope still matches what the company actually does. Have the advisory team read the current published text against your registration documents, item by item.
Related
Sources
- Department of Business Development (DBD), law database, Ministerial Regulation Prescribing Service Businesses Not Requiring a Licence for Foreign Business Operation (No. 5) B.E. 2569, Royal Gazette Vol. 143 Part 51 Kor, pp. 31-34 (published 28 August 2026, signed 18 August 2026), retrieved and checked 2026-10-20
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中文版 · Chinese version