Thailand’s Renewed BOI Incentives: How to Prepare for 2026 & 2027

Thailand’s Board of Investment (BOI) has been the cornerstone of the nation’s economic development. Throughout the years, Thailand has become an industrial powerhouse in Southeast Asia with a record-breaking performance in the current decade. In 2024, investment applications surged by 35% reaching a ten-year high valued at THB 1.14 trillion (approximately USD 33 billion). This momentum is also reflected within the first nine months of 2025, with a THB 1.37 trillion investment application – the highest level on record in Thailand’s BOI history. 

To bolster this growth, BOI in Thailand is opening a “strategic window” in 2026 and 2027, focusing on three major shifts: 

1. The global enforcement of the OECD’s Pillar Two (Global Minimum Tax) 
2. Radical restructuring of regional supply chains away from single-source dependencies
3. Thailand’s own aggressive pivot toward a “New Economy”

The incentives available in this two-year window are designed to reward early movers and large-scale commitments. If you are planning an expansion or a relocation, waiting until 2028 will likely mean missing out on the most lucrative tax-shielding mechanisms currently on the table.

In this article, we will talk about renewed BOI incentives in Thailand. We will cover what are flagship measures to these changes in BOI, shifts in fiscal and non-fiscal incentives, and high-priority sectors in 2026-2027. 

Strategic Measures for Foreign Investors in 2026-2027

The BOI’s current strategy is defined by three pillars: Innovation, Competitiveness, and Inclusiveness. While these sound like typical government buzzwords, they translate into very specific financial benefits for your business.

During this period, Thailand will be transitioning from a traditional tax-exemption model to a “Refundable Tax Credit” system to comply with the Global Minimum Tax (GMT) of 15% for multinational enterprises (MNEs). During this transition, the BOI is offering “Retention and Expansion” and “Relocation” packages that are effectively the last of their kind.

These measures are designed to be “additive”. This means, it builds upon the standard incentives already provided to high-tech activities.

A. Retention and Expansion Program

This is a “loyalty” program aimed at established multinational investors. The BOI has realized that retaining existing capital is as important as attracting new ones.

From a strategic perspective, this is the government acknowledging that long-term partners deserve better than “first-time” rates. If your group has a footprint in Thailand, this is the time to consolidate your regional manufacturing here rather than looking at Vietnam or Indonesia.

• Eligibility: You must have been a promoted entity for at least 15 years with a track record of at least three promoted projects. The combined investment value of these projects must exceed THB 10 billion.
• The Incentive: If you propose a new expansion project worth at least THB 500 million, you are eligible for an additional Corporate Income Tax (CIT) exemption of 3 years or a 50% CIT reduction for 5 years.
• The Window: This is a strictly time-bound offer. Applications must be submitted before the final working day of 2027.

B. Comprehensive Business Relocation Measure

This measure targets companies looking to move more than just a factory. This incentive is designed to consolidate both regional management functions and core manufacturing operations within Thailand. It’s like consolidating the “brain” and the “body” of your company in Thailand. The BOI is essentially offering a bonus for those who commit to making Thailand their primary regional node.

• The Requirement: You must simultaneously apply for a manufacturing project and an International Business Center (IBC) project. The relocation must involve significant operations, including regional headquarters or high-level technical support functions.
• The Incentive: Projects qualifying for standard incentives in Groups A1, A2, or A3 can receive an additional 5 years of CIT exemption. For Group A4 (generally lower-tech manufacturing), the bonus is 3 additional years.
• The Logic: By forcing the pairing of an IBC with manufacturing, Thailand ensures that high-paid executive roles and regional decision-making remain within its borders.

C. Economic Recovery Stimulation Measure

This is a “high-speed” capital injection measure. It is designed for projects that are ready to break ground immediately and helps the government demonstrate immediate FDI (Foreign Direct Investment) growth.

• The Requirement: A minimum investment of THB 2 billion (excluding land and working capital). Crucially, the actual investment must be completed within 12 months of the promotion certificate being issued.
• The Incentive: An additional 50% CIT reduction for 5 years after the initial tax holiday expires.
• The Deadline: Applications for this specific stimulus are only open until the end of 2026. This is the tightest window available.

Navigating the OECD Pillar Two (Global Minimum Tax) Shift

The global tax landscape is undergoing a fundamental overhaul with the implementation of the  Organisation for Economic Co-operation and Development (OECDs) Pillar Two. This global minimum tax framework ensures MNEs pay at least 15% effective tax on profits in every jurisdiction.

If your group revenue exceeds EUR 750 million, the traditional “0% tax for 13 years” incentive is no longer a pure benefit. Under the Global Minimum Tax (GMT) rules, if a subsidiary’s effective tax rate in Thailand falls below 15%, the “Top-up Tax” mechanism allows your home jurisdiction to collect the difference. 

This renders traditional tax exemptions effectively moot for large MNEs. Failing to recalibrate your incentive strategy could lead to a higher compliance burden without any actual reduction in your global effective tax rate.

Qualified Refundable Tax Credit (QRTC)

As a response, Thailand is implementing the Qualified Refundable Tax Credit (QRTC). This represents a fundamental shift in how Thailand competes for investment.

• From Holidays to Credits: Instead of simply not paying tax, you will pay the required 15% but receive credits based on “Qualifying Expenditures.”
• Qualifying Expenditures: These include investments in R&D, advanced staff training in STEM, and the implementation of “Green Technology” (such as on-site carbon capture or solar arrays).
• The Cash Option: Crucially, if the credits exceed your tax liability, the BOI is designing a mechanism where the excess can be paid out as a cash grant. For a consultant, this is the most critical area of planning. Your financial model must now account for “tax-inclusive” costs balanced against “credit-based” recoveries.

Overall, the strategy should shift from “finding the longest tax holiday” to “maximizing qualifying expenditures” that trigger these refundable credits.

High-Priority Sectors: The “Red Carpet” Treatment

Thailand’s BOI classifies promoted activities into various tiers. Higher tiers (A1+, A1) offer longer exemptions (up to 13 years, uncapped) for strategic sectors like frontier tech, biotech, and EVs. Meanwhile lower tiers (A4, B) provide shorter or no CIT holidays but retain non-tax perks.​

To get the maximum 13-year exemption (Group A1+), your project must fall into very specific categories that align with Thailand’s 2030 vision.

A. Advanced Electronics and Semiconductors

Following the 2024–2025 updates, the BOI has specifically targeted the “Front-end” of electronics. This represents a significant move up the value chain from traditional “Back-end” activities like assembly, testing, and packaging (ATP). This means, Thailand is now focusing on the chemistry and physics of computing instead of simply soldering circuit boards. 

Here are some industries that are being prioritized in advanced electronics and semiconductors in Thailand:

• Wafer Fabrication: These projects are automatically eligible for Group A1+ (up to 13 years of CIT exemption).
• Electronic Design: Designing circuits or software-hardware integration is prioritized.
• Machinery Flexibility: For electronics, the BOI now allows the use of high-quality used machinery (not exceeding 10 years old) to be counted as part of the investment value, recognizing that the lifecycle of semiconductor equipment is unique.

B. Electric Vehicles (EV) and the “30@30” Policy

Thailand aims for 30% of its car production to be zero-emission by 2030 under the ambitious “30@30” policy. To support this initiative, Thailand is leveraging its manufacturing roots to lead the regional transition toward electric mobility.

Incentives are focused on the EVs supply chain and prioritize its core components. This includes the localized production of battery cells, battery modules, drive motors, thermal management systems, and high-voltage wiring harnesses. By targeting these upstream elements, the BOI aims to build a resilient domestic ecosystem that reduces dependency on imported power electronics and high-value electrochemical parts.

To mitigate “range anxiety” from consumers, the Thai government is also supporting companies who establish charging stations in Thailand. Organizations with a network of at least 40 charging stations receive a 5-year CIT exemption. To ensure this infrastructure is technologically relevant, a minimum of 20 units must be DC fast-chargers. 

C. Digital Infrastructure and Data Centers

The rise of AI has made Thailand a regional hub for cloud services, specifically targeting providers moving away from land-constrained hubs like Singapore.

• Requirements: To qualify for 8 years of CIT exemption, data centers must have a minimum investment of THB 500 million and meet international standards (TIA-942 or Uptime Institute Tier III/IV).
• Sustainability: There is an increasing focus on the Power Usage Effectiveness (PUE) ratio. Projects with a PUE below 1.5 receive “Smart and Sustainable” top-up benefits.

Starting a Company in Thailand in 2026 and 2027

2026 and 2027 are crucial periods to start a new company in Thailand, especially for MNCs in critical sectors. To assist you in starting a BOI company in Thailand, our experts at Emerhub can help you through different phases of the setup process. From pre-application, submission, to finally receiving your “Letter of Approval” from BOI. 

Our local compliance experts will also help you with post-registration compliance. We will help you submit an annual investment report, as well as provide information on how to maximize your CIT. 

Start your plans to expand your business in Thailand in 2026. Get in touch with our local team in Thailand for a free consultation.