Home / Statutory Framework
04 REGULATORY COMPLIANCE

Genuine partnerships — never nominee arrangements.

Thai law does not prohibit foreigners from doing business in Thailand. It prohibits pretending. This page explains the fundamental statute everything here is built around, why it exists, and which lawful routes are available to you.

Primary statute FBA B.E. 2542
Key provision Section 36
Enforcement order DBD Order 2/2569
Statutory penalty Up to 3 yrs · 1M ฿
Jump to: FBA Section 36 Nominee test Lawful routes Our policy Live updates feed
01 STATUTORY ANCHOR

The rule everything is built around.

The Foreign Business Act reserves specific business activities for Thai nationals and governs foreign corporate participation.

Foreign Business Act B.E. 2542 · Regulatory Scope

Why the 51/49 funding structure matters.

A company is deemed foreign when foreign nationals hold 50% or more of shares. In a 51/49 structure, how those 51% are funded and controlled matters vastly more than what appears on paper.

Foreign Business Licence (FBL) BOI Promotion Treaty of Amity (US) Genuine 51/49 JV
FBA B.E. 2542 · Section 36 Statutory Text

"Any Thai national or juristic person who holds shares in a foreign business on behalf of, or in concert with, a foreigner… shall be liable to imprisonment for a term not exceeding three years, or to a fine of one hundred thousand to one million baht, or to both."

02 SUBSTANCE OVER FORM

What counts as a nominee arrangement.

Thai regulators evaluate economic reality, not superficial paperwork. An arrangement is classified as a nominee structure when any of these conditions are met:

1. Subsidized Capital

The foreign party provides the funds the Thai shareholder uses to purchase their equity, whether as an off-record loan or gift.

2. Loss Guarantees

The Thai shareholder is protected from downside loss or has a side agreement to be bought out at a guaranteed rate.

3. Undated Share Pledges

The Thai shareholder signs blank, undated transfer deeds or pledges shares to the foreign investor.

4. Disenfranchised Governance

Voting mechanisms or board structures prevent the Thai majority from exercising legitimate shareholder control.

Comparison of a nominee shortcut versus a real partnership with capital from both sides and shared governance
Nominee shortcut vs real partnership — research framing; verifiable equity protects both parties.
Why Question 3 Ends Non-Compliant Applications Immediately

Our eligibility questionnaire directly asks whether you intend to fund your Thai partner's shares, or whether a third party is financing the capital. Answering yes immediately halts the intake process. It cannot be resolved later by clever drafting.

03 COMPLIANT STRUCTURES

The four lawful routes.

Four legal pathways exist for lawful foreign business participation in Thailand:

Genuine 51/49 Joint Venture

The Thai partner invests personal capital, takes real economic risk, and holds legitimate voting rights. Minority protections are enforced via robust shareholder agreements (reserved matters, tag-along/drag-along, deadlock arbitration) rather than nominee control.

Foreign Business Licence (FBL)

A formal licence issued by the Ministry of Commerce permitting majority foreign ownership in specified restricted sectors.

BOI Promotion

Board of Investment privileges grant 100% foreign ownership, land ownership rights, and corporate tax exemptions for qualifying industries.

Treaty of Amity (US Nationals)

Grants American citizens and US-majority corporate entities the right to maintain majority ownership in most commercial activities.

04 OPERATIONAL INTEGRITY

Our strict screening policy.

Standardized verification protocols maintained across all client files.

Zero Funding of Counterparties

We decline any applicant attempting to finance or guarantee the counterparty's equity holding.

Mandatory Proof of Funds

Zero introductions occur before both sides furnish 3–6 month bank statements proving independent capital.

Dual-File Legal Review

All shareholder agreements are drafted and scrutinized by licensed Thai counsel with full visibility into both files.

Verify your eligibility under Thai law.

Complete the baseline 5-minute intake check. No sensitive files or documents are required at this stage.