Thailand Specific Business Tax (SBT / ภ.ธ.): Who Pays, Tax Base and Rates

Specific business tax (SBT; Thai ภ.ธ.) is an "assessed tax" under Thailand's Revenue Code that applies to specific industries such as banking, finance and securities, life insurance, pawnbroking, and the buying and selling of immovable property. It is charged on gross revenue at tiered rates in place of value added tax (VAT).

Under the Revenue Code, specific business tax is an assessed tax (Section 91); any person conducting a specific business listed in Section 91/2 within the Kingdom is subject to specific business tax rather than VAT, and must file and pay monthly (Section 91/10).

1. What specific business tax (SBT / ภ.ธ.) is

Specific business tax (SBT; Thai abbreviation ภ.ธ.) is, like value added tax, an indirect tax under Thailand's Revenue Code. Section 91 provides that specific business tax is an "assessed tax". It does not apply to all operators; instead, under Section 91/2 it is specifically assigned to certain industries such as finance and immovable property—these industries fall outside the VAT system and pay specific business tax instead. Therefore, when deciding whether a given business should pay VAT or SBT, the first step is to check whether it falls within the list in Section 91/2.

2. Which businesses pay SBT rather than VAT (Section 91/2)

Section 91/2 lists the types of business subject to specific business tax, concentrated mainly in the finance and immovable property sectors:

Banking business: banking business conducted under the law on commercial banking or a specific law (Section 91/2).
Finance, securities and finance credit business: finance, securities or credit business conducted under the relevant laws (Section 91/2).
Life insurance business: life insurance business conducted under the law on life insurance (Section 91/2).
Pawnbroking (pawnshops): pawnbroking conducted under the law on pawnshops (Section 91/2).
Bank-like business: business conducted in the ordinary manner as a commercial bank, such as lending money, providing guarantees, exchanging currency, issuing or buying and selling promissory notes and debt instruments, or remitting money abroad by various methods (Section 91/2).
Buying and selling immovable property: buying and selling immovable property as trade or for profit (regardless of the method by which the property is acquired), in accordance with the criteria, procedures and conditions prescribed by royal decree (Section 91/2).
Selling securities on the stock exchange: selling securities in the stock exchange under the law on the Stock Exchange of Thailand (Section 91/2).
Other business prescribed by royal decree (Section 91/2).

In addition, Section 91/2 also provides that a person located outside the Kingdom who conducts the above business through a place of business or agent located in the Kingdom is deemed to conduct business in the Kingdom, and is likewise subject to SBT. Note that the above scope is subject to Section 91/4—that is, certain businesses may be exempted or treated separately under that section, with the exact scope governed by the official rules (our firm can assist in confirming).

3. Tax base: charged on gross revenue (Section 91/5)

Section 91/5 provides that the tax base for specific business tax is the revenue "received or deemed received" by the taxpayer from conducting the above business. This differs fundamentally from VAT, which is charged on the "value added"—SBT is charged on gross revenue: for example, banking is taxed on interest, discount, commission and service fees, as well as profit from buying and selling promissory notes/debt instruments and foreign exchange; while buying and selling immovable property and selling securities on the exchange are taxed on "revenue before deduction of any expenses whatsoever" (Section 91/5). Because the tax base is gross revenue, the taxpayer generally cannot offset input tax as under VAT.

4. Tax rates: three tiers by business type (Section 91/6)

Section 91/6 does not apply a single rate to all businesses, but sets three statutory rate tiers by business type:

Securities trading 0.1%

Revenue from selling securities on the stock exchange (Section 91/5 (7)), taxed at 0.1% (Section 91/6 (1)).

Life insurance · Pawnshops 2.5%

Interest/commission/service-fee revenue from life insurance, and pawnshop business revenue (Section 91/5 (3)(4)), taxed at 2.5% (Section 91/6 (2)).

Other businesses 3.0%

Banking, finance and securities, bank-like business, buying and selling immovable property and the other remaining cases, taxed at 3.0% (Section 91/6 (3)).

Note: the above are the statutory base rates set out in Section 91/6 of the Revenue Code. In Thai practice, some businesses may also be subject to an additional local (municipal) surcharge under other laws, making the actual tax burden higher than the base rate; this surcharge rate, and any special or adjusted rate that may apply under a royal decree to businesses such as buying and selling immovable property, are all governed by the official rules (our firm can assist in confirming).

5. Monthly filing and payment (Section 91/10)

Section 91/10 provides that a specific business taxpayer must file and pay tax monthly using the form prescribed by the Director-General (in practice, the monthly specific business tax return, Thai ภ.ธ.40 / PT40), and must file regardless of whether there is income in that month. Filing and payment for each tax month must be made within the fifteenth day of the following month, unless the Director-General prescribes otherwise; filing takes place at the district revenue office in the area where the place of business is located, and a taxpayer with multiple places of business must, in principle, file separately for each (Section 91/10).

Immovable property exception: the business of buying and selling immovable property (Section 91/2 (6)) is not filed monthly; instead, at the time of registering rights and juristic acts concerning immovable property, the taxpayer files using the form prescribed by the Director-General and pays the tax to the official who handles the registration. The Land Department collects this tax on behalf of the Revenue Department, and registration will not proceed until the tax is paid in full (Section 91/10).

⚠️ Note

Whether a given business falls within the SBT taxable scope, which rate tier applies, and how SBT on an immovable property transaction is calculated, paid and timed against registration all need to be confirmed case by case against the specific facts and the latest royal decrees—our firm can assist in making the determination and handling the filing.

FAQ

What is the difference between specific business tax (SBT) and value added tax (VAT)?

Both are indirect taxes under Thailand's Revenue Code, but they apply to different parties and are calculated differently. Under Section 91, SBT is an assessed tax; under Section 91/2, it applies specifically to certain industries such as banking, finance and securities, life insurance, pawnbroking and the buying and selling of immovable property, which pay SBT instead of being brought into the VAT system. As for calculation, VAT is charged on the value added and allows input tax credit, whereas under Section 91/5 SBT is charged on gross revenue and generally cannot be credited.

Which businesses pay specific business tax instead of value added tax?

Under Section 91/2, they mainly include: banking business; finance/securities/finance credit business; life insurance; pawnbroking; bank-like business conducted in the ordinary manner as a commercial bank (lending, guarantees, currency exchange, buying and selling promissory notes, remitting money abroad, etc.); buying and selling immovable property for profit; selling securities on the stock exchange; and other business prescribed separately by royal decree. A person located outside the Kingdom who operates through a place of business or agent in Thailand is also deemed to conduct business in the Kingdom.

What are the specific business tax rates?

Under Section 91/6, SBT is set in three tiers by business type: securities trading 0.1%; life insurance and pawnshops 2.5%; and banking, finance, bank-like business, buying and selling immovable property and other remaining businesses 3.0%. These are the statutory base rates; in practice some businesses may also incur a local (municipal) surcharge under other laws, and businesses such as immovable property may be subject to special rates under a royal decree, so the actual tax burden and specific application are governed by the official rules—our firm can assist in confirming.

How is specific business tax filed and paid?

Under Section 91/10, the taxpayer must file and pay monthly using the form prescribed by the Director-General (in practice ภ.ธ.40 / PT40), regardless of whether there is income that month, within the fifteenth day of the following month at the district revenue office in the area where the place of business is located; a taxpayer with multiple places of business files separately for each in principle. Buying and selling immovable property is an exception: the tax is filed and paid at the time of title registration, collected by the Land Department, and registration will not proceed until the tax is paid in full.