Export Company in Thailand: 100% Foreign Ownership Without a Local Partner (2026)

A Russian entrepreneur buys dried mango from a factory in Rayong and ships it by container to Almaty and Warsaw. His first question to a lawyer is always the same: where do I find a Thai partner to hold 51%?

Nowhere. If not a single kilogram of the product is sold inside Thailand, the company can be 100% foreign-owned. No Foreign Business License, no nominee Thai shareholders, no extra permits.

The logic of the 1999 Foreign Business Act (FBA) is straightforward: the restrictions under List 3 apply to trading within the domestic market. Sales made outside the country fall outside those restrictions. That is exactly why Thai lawyers refer to this setup as an export-only company.

There is one clause that can unravel the whole structure: a single domestic sale is enough to break it. Sell a trial batch to a Thai distributor, offload leftover stock to a local cafe, take a deposit from a Bangkok buyer, and the company is now conducting wholesale or retail trade inside Thailand. From there, you either need a license, a Thai-majority ownership structure, or you are taking on real risk. Nominee shareholding under Section 36 of the FBA carries a fine of up to 1 million THB and up to three years in prison, and the Department of Business Development is checking the source of funds behind Thai shareholders more aggressively than ever.

Quick Answer

• 100% foreign ownership is available to a Thai company that sells its product exclusively outside Thailand. No Foreign Business License required.

• No Thai partner is needed, either in the share capital or on the board of directors.

• Exports are zero-rated for VAT (0%), while input VAT (7%) paid on purchases from Thai suppliers is refundable once the company registers as a VAT operator.

• 2 million THB in registered capital is required per work permit issued to a foreign employee, plus four Thai staff hired per foreign worker. If you manage the business remotely, the bar is lower.

• Thailand's exports reached 339.6 billion USD in 2025, up 12.9% year-on-year.

• Free trade agreements with ASEAN, China, Japan, Australia, and RCEP partners deliver reduced tariffs when a certificate of origin is presented.

Key Facts

• A private limited company now needs a minimum of two shareholders: an amendment to the Civil and Commercial Code, effective February 2023, removed the previous requirement for three founders.

• The corporate tax rate is 20%. Companies with paid-up capital under 5 million THB and annual revenue under 30 million THB benefit from a progressive scale: the first 300,000 THB of profit is tax-exempt, with 15% applied up to 3 million THB.

• Mandatory VAT registration kicks in at 1.8 million THB in annual turnover. Exporters are usually better off registering voluntarily from day one, otherwise input VAT simply sits in the cost base.

• Shipments require registration with the Customs Department's e-Customs (Paperless) system and a digital certificate. Without it, no export declaration can be filed.

• Every Thai company must keep proper books and file an audited annual financial statement, even with zero revenue.

• Thailand's leading export categories include electrical and electronic equipment, automobiles and auto parts, natural rubber and rubber products, gems and jewelry, plastics and chemicals, and agri-food and seafood.

Now for the less comfortable part. A record year like 2025 is a poor baseline for forecasting. Market estimates suggest a meaningful share of that growth came from buyers front-loading shipments ahead of new US tariffs, stocking up warehouses in advance. I would not build a financial model on extrapolating that 12.9% growth rate forward.

The second catch concerns VAT refunds. The right to a refund exists, but the Revenue Department routinely places new exporters under desk audit, and the money does not land the following month. It typically takes several months, sometimes only after supporting documents for each shipment are requested. Treat this as a cash flow gap and budget working capital accordingly.

It is worth noting that scrutiny of foreign-linked corporate structures in Thailand is intensifying more broadly: the Department of Business Development has reportedly opened review of over 36,000 foreign-connected companies holding land rights, focused on structures where Thai nominee shareholders mask real foreign control. An export-only company with no land ownership sits outside that particular risk, but it signals the direction regulators are moving in across the board.

How to Start: Step by Step

1. Put the export model on paper. State export and related operations in the company's objectives, and explicitly exclude wholesale or retail trade within Thailand. This is the document any inspector will look at first.

2. Reserve a company name with the Department of Business Development (DBD). The reservation is valid for 30 days.

3. Set the capital. No foreign staff based in the country? A nominal amount is enough. Need a work permit and a Non-B visa? Budget 2 million THB per foreign employee and plan to hire four Thai staff for each one.

4. Register the company. Memorandum, founders' meeting, registration. With documents and signatures ready, the process takes only a few days.

5. Get a tax ID and register for VAT with the Revenue Department. Without VAT-registered status, the zero rate on exports gets you nothing.

6. Open a corporate bank account. Thai banks require the director's personal presence, the company charter, a list of shareholders, and a clear description of your goods flow. This is usually the step that requires an actual trip, and it rarely closes in a single visit.

7. Register with Customs as an exporter, set up a digital certificate, and choose a customs broker. A first declaration with a wrong HS code can cost days of container downtime.

8. Check product-specific licensing. Food and cosmetics go through Thailand's FDA; timber, rubber, and certain agricultural goods require export permits from the relevant ministries. There is no universal rule, it depends on the product code.

9. Draft contracts under Incoterms 2020 and request certificates of origin from suppliers: Form D for ASEAN, Form E for China, or the RCEP form. The tariff difference your buyer saves is often exactly your margin.

10. Set up bookkeeping from month one. Monthly PP.30 filings, withholding tax, employee social security, and annual audit.

My recommendation: if first-year turnover is expected in the 30-50 million THB range and you are trading someone else's goods, a standard export-only company without BOI promotion is the right call. It is cheaper, registers faster, and does not tie you to reporting obligations toward the investment board. Going through BOI makes sense once you plan to manufacture in Thailand, hold land for a factory, or import equipment duty-free. And there is one case where none of this applies to you at all: if you expect to sell part of your batches to local Thai clients, the structure needs to be designed differently from day one, not patched after the fact.

FAQ

Do I need a Thai partner for an export company?

No. As long as the company does not sell goods inside Thailand, 100% of the shares can belong to a foreigner, and no Foreign Business License is required.

Can I buy raw materials in Thailand and reclaim the VAT?

Yes. Purchases from Thai suppliers carry 7% VAT, export shipments are zero-rated, and the difference is refunded to a registered VAT payer. In practice, first-time refunds come with an audit and arrive with a delay of several months.

How much money do I need to start?

The legal minimum capital for a trading company is modest, but the real threshold is set by work permits: 2 million THB per foreign employee working in Thailand, plus registration fees, bookkeeping, and the annual audit.

Do I have to live in Thailand?

No. The company can be managed remotely, with you appointed as director, and no work permit is needed if you are not physically performing work inside the country. You will still need to travel at least once to open a bank account.

What happens if I sell a batch domestically?

You fall outside the exception and into the restrictions of FBA List 3. Your options are: obtain a Foreign Business License, restructure ownership, or stick to exports only. Nominee shareholder schemes are punishable by a fine of up to 1 million THB and up to three years in prison.

How long does registration take?

Company registration itself, with a full set of documents, takes a matter of business days. VAT registration, customs registration, and the bank account typically stretch the launch to several weeks, with the bank usually being the slowest step.

Does an export company come with a visa?

Not automatically. The Non-B visa and work permit are separate processes and require meeting conditions on capital and Thai staff hiring.

What goods are easiest to export from Thailand?

The most established supply chains cover auto parts, electronics, natural rubber products, plastics, processed agri-food, and seafood. For food and cosmetics, build in extra time for approvals from Thailand's FDA.

Source: Realty-Phuket.com

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