BOI Thailand AI Investment Incentives: Tax Benefits for AI Companies
Thailand's Board of Investment offers some of the most generous incentives in ASEAN for companies investing in artificial intelligence. Under BOI Activity 5.10 and related digital technology categories, AI companies can receive up to 8 years of corporate income tax exemption with no cap, plus additional benefits for R&D and staff training. This guide details every AI-specific BOI incentive available in 2026.
- Companies developing AI software, platforms, or digital content in Thailand
- R&D centres conducting AI research with qualified Thai and foreign researchers
- Minimum investment of THB 1 million (excluding land and working capital)
- Must employ Thai nationals in skilled positions
- Must use modern technology and processes
- Must comply with Thai environmental and safety regulations
- Identify the appropriate BOI promoted activity (e.g., Activity 5.10 for AI software)
- Prepare a detailed AI business plan with technology description and workforce plan
- Submit application through the BOI e-Filing system with supporting documents
- BOI evaluates the application (40-90 working days depending on project size)
- Receive Promotion Certificate specifying incentive tier and conditions
- Register AI training programmes with the Department of Skill Development (DSD)
- Claim 200% training deduction and track CIT exemption usage annually
- Submit annual operating reports to maintain BOI promotion status
BOI's AI and Digital Technology Focus
Thailand's Board of Investment has made artificial intelligence and digital technology a cornerstone of its investment promotion strategy since the launch of Thailand 4.0 in 2016. By 2026, the BOI has refined its AI-specific incentives to attract both international AI companies establishing operations in Thailand and domestic companies investing in AI capabilities.
The BOI recognises AI as a foundational technology that enhances competitiveness across all sectors. Accordingly, AI-related activities receive Group A1 or A2 incentives — the highest tier — reflecting Thailand's strategic priority to become a regional AI hub.
BOI Activity 5.10: Software, Digital Platforms, and Digital Content
Activity 5.10 is the primary BOI category for AI and software companies. It covers:
5.10.1 — Software Development (Group A1/A2)
Group A1 incentives (maximum) are granted when the software involves:
- Artificial intelligence and machine learning systems
- Embedded software for smart devices and IoT
- Enterprise software with advanced analytics
- Cybersecurity software
- Cloud platform development
Incentive package:
- CIT exemption for 8 years with no cap on exempt amount
- Import duty exemption on machinery and equipment
- Additional 1-3 years CIT exemption through merit-based enhancements
- Total possible CIT exemption: up to 13 years
Group A2 incentives for general software:
- CIT exemption for 8 years capped at the investment amount
- Import duty exemption on machinery
5.10.2 — Digital Platforms (Group A1/A2)
AI-powered digital platforms receive top-tier incentives:
- SaaS platforms with AI capabilities
- AI marketplaces and API services
- Digital health platforms using AI diagnostics
- Fintech platforms with AI-powered risk assessment
- EdTech platforms with personalised AI learning
5.10.3 — Digital Content Creation (Group A2/A3)
AI-enhanced content creation activities:
- Generative AI content platforms
- AI-assisted animation and visual effects
- AI-powered game development
- Natural language processing for content localisation
BOI Activity 5.8: R&D Centres and Design
Companies establishing AI research and development centres in Thailand receive some of the most generous incentive packages:
R&D Centre (Group A1)
- CIT exemption for 8 years with no cap
- 200% deduction on R&D expenditures
- Import duty exemption on all R&D equipment and materials
- Fast-track work permits for foreign researchers
- Additional CIT exemption for R&D spending above THB 200 million
Qualifying AI R&D activities:
- Fundamental AI research (machine learning algorithms, neural network architectures)
- Applied AI research (industry-specific AI applications)
- AI model training and fine-tuning for Thai language and context
- AI testing and evaluation laboratories
- Human-AI interaction research
Design and Engineering Centre (Group A1/A2)
- CIT exemption for 5-8 years
- Covers AI system design, UX for AI products, and AI chip design
- Import duty exemption on design tools and hardware
Tax Holidays: How CIT Exemption Works for AI Companies
During the CIT Exemption Period
For the duration of the tax holiday (up to 8 years from first revenue), the BOI-promoted AI company pays zero corporate income tax on income from the promoted activity. This includes:
- Revenue from AI software licenses and subscriptions
- Revenue from AI consulting and implementation services (if part of the promoted activity)
- Revenue from AI platform usage fees
- Revenue from AI-related training services
Important: Non-promoted income (e.g., revenue from activities not covered by the BOI certificate) is taxed at the standard 20% CIT rate.
After the CIT Exemption Period
Many AI companies qualify for additional benefits after the base exemption:
- 50% CIT reduction for 5 additional years (Group A1)
- Further reductions if located in EEC or special zones
- Ongoing 200% deduction for training and R&D expenses
Merit-Based CIT Extension for AI Training
The BOI specifically rewards companies that invest in training Thai employees in advanced skills. AI companies can earn 1-3 additional years of CIT exemption by meeting training investment thresholds:
1 additional year: Annual training spend of at least 1% of total payroll 2 additional years: Annual training spend of at least 2% of total payroll or THB 5 million 3 additional years: Annual training spend of at least 3% of total payroll or collaborative training with Thai educational institutions
This is one of the most powerful incentives for AI companies, as training is already a core business need. By structuring training programmes to meet BOI criteria, companies effectively extend their tax holiday while building workforce capabilities.
The 200% Training Expense Deduction
All BOI-promoted AI companies can claim a 200% deduction on qualifying training expenses. This means for every THB 1 spent on approved training, the company deducts THB 2 from taxable income.
What Qualifies as AI Training Under BOI
- AI and machine learning courses for Thai employees
- Data science and analytics training
- Cloud computing and AI infrastructure skills
- AI ethics and governance training
- Industry-specific AI application training (e.g., AI for finance, AI for manufacturing)
- International AI certification programmes
- Training delivered by approved foreign or domestic providers
Documentation Requirements
To claim the 200% deduction, companies must:
- Register the training programme with the Department of Skill Development (DSD)
- Maintain records of training hours, participants, and costs
- Obtain certificates of completion for each participant
- Include training details in the annual BOI operating report
Comparison with Regional AI Incentives
Thailand's BOI AI incentives are among the most competitive in ASEAN:
| Country | Max CIT Exemption | Training Incentive | Foreign Ownership |
|---|---|---|---|
| Thailand (BOI) | 13 years | 200% deduction | 100% allowed |
| Singapore | Varies (pioneer status) | Up to 400% deduction (IBG) | 100% allowed |
| Malaysia (MDEC) | 10 years | Double deduction | Subject to equity guidelines |
| Vietnam | 4 years | Limited | Subject to investment law |
| Indonesia | 5-20 years (tax holiday) | Limited | Subject to negative list |
Thailand's combination of long CIT exemption periods, the 200% training deduction, and full foreign ownership make it uniquely attractive for AI companies seeking a Southeast Asian base.
How Pertama Partners Helps AI Companies Maximise BOI Benefits
Pertama Partners delivers AI training that is structured to qualify for BOI incentive claims. We help AI companies and technology investors in Thailand:
- Design training programmes that meet BOI merit-based enhancement criteria for additional CIT exemption years
- Structure training documentation for 200% expense deduction claims
- Provide certified AI training that satisfies DSD registration requirements
- Deploy international AI experts under BOI work permit facilitation
- Advise on combining BOI incentives with EEC and Digital Park Thailand benefits
Contact us to maximise the value of your BOI-promoted AI investment in Thailand.
Frequently Asked Questions
Frequently Asked Questions
For software and digital platform activities (Activity 5.10), the minimum investment is typically THB 1 million excluding land and working capital. For R&D centres (Activity 5.8), the minimum is also THB 1 million but the BOI expects a credible R&D plan with qualified personnel. These thresholds are relatively low compared to manufacturing, reflecting the BOI's priority for knowledge-based investments.
Yes. Existing companies can apply for BOI promotion for a new AI-related activity or project. The key requirement is that the promoted activity must be distinct and separately tracked from existing non-promoted activities. Many companies set up a new division or subsidiary for the BOI-promoted AI project.
AI consulting and implementation services can be included as part of a BOI-promoted activity if they are ancillary to the primary promoted activity (e.g., software development). Standalone training services may qualify under other BOI categories such as Activity 5.8 (R&D and training centres) or Activity 7.10 (vocational training). Pertama Partners can advise on the best structure.
BOI-promoted companies must still comply with Thai transfer pricing regulations. Income from the promoted activity must be calculated at arm's length prices. The Revenue Department actively reviews BOI-promoted companies to ensure promoted and non-promoted income are properly separated. Proper documentation and accounting segregation are essential.
Yes, and this is actually an ideal time to apply. The CIT exemption period begins from the date of first revenue from the promoted activity, not from the date of approval. Pre-revenue startups can secure their BOI promotion while still developing their product, ensuring they receive the full benefit period once they begin generating income.
- •AI and Machine Learning for Software Teams
- •Deep Learning and Neural Network Engineering
- •Natural Language Processing for Thai Language
- •Computer Vision Development and Deployment
- •AI Product Management and Strategy
- •Data Engineering for AI Pipelines
- •AI Ethics, Governance, and Responsible AI
- •Cloud AI Infrastructure (AWS, GCP, Azure)
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