Can a Trading or Service Business Get BOI Promotion? The TISO Explained

A TISO is the BOI route for trading, sourcing, and support businesses. It gets you up to 100% foreign ownership and easier work permits, but no corporate tax holiday.

BOI is often written off as a scheme for factories and tech companies. Plenty of trading, sourcing, advisory, and support businesses fit it too, and the route for them is the Trade and Investment Support Office, or TISO. It’s a promoted activity built for companies that don’t manufacture anything, and it doesn’t require you to own a single machine.

What a TISO gets you is the non-tax side of BOI: up to 100% foreign ownership in activities normally closed to foreigners, and work permits for your foreign staff without the usual capital-and-Thai-staff ratios. For a small foreign-run services or wholesale business, that combination is often the whole reason to bother with BOI.

What it doesn’t get you is a tax holiday. A TISO sits in Group B, so your profits are taxed at the normal 20%, the same as any ordinary Thai company. Any setup firm that pitches “BOI tax benefits” for a trading business is glossing over that, and it’s the first thing to be clear about before you commit.

This guide walks through the whole thing: what a TISO is and what it lets you do, what it takes to qualify, the tax catch, how it compares to the IPO and IBC, and how to apply. By the end you’ll know whether a TISO is the right structure for your business, or whether a plain Thai company would serve you better.

What a TISO Actually Is

TISO stands for Trade and Investment Support Office. In the BOI’s activity list it sits in the professional services category as activity 10.1.1. Think of it as the promoted home for the businesses that support trade and investment rather than manufacture goods: the consultants, the sourcing agents, the technical-support arms of overseas groups, and the wholesalers of Thai-made or affiliated products.

This matters because so many foreign founders assume BOI is off-limits to them. You don’t have a factory, you don’t hold patents, so you write BOI off and set up a plain Thai company with Thai majority shareholders or, worse, a nominee arrangement. A TISO is often the cleaner answer. It’s still a normal Thai private limited company; the BOI promotion just sits on top of it and unlocks the perks. For the wider picture of how that works, start with our guide on what BOI is.

The whole point of a TISO is the non-tax side of BOI. You’re not chasing a tax holiday here (more on that below). You’re after the ownership and staffing freedom that a plain Thai company can’t give a foreigner.

What a TISO Can Cover

The BOI defines the TISO scope tightly. Your business plan has to fall inside one or more of these activities:

• Monitoring and servicing your affiliated companies, including renting office or factory space to them and certain intra-group lending under the exchange-control rules.
• Advisory services on business operations. This one carves out the regulated professions: no securities trading, foreign exchange, accounting, legal, advertising, or architectural and civil engineering advice.
• Information services on sourcing goods.
• Engineering and technical services, again excluding architectural and civil engineering.
• Machinery-related activities for equipment made by an affiliate or an officially authorised manufacturer: importing for wholesale, training, installation, maintenance and repair, or calibration.
• Wholesaling products manufactured in Thailand.
• International business process outsourcing over telecom networks: administration, finance and accounting, HR, sales and marketing, customer service, and data processing.

Two things stand out. First, the wholesale allowance is specific: you can wholesale goods made in Thailand, or wholesale machinery from your affiliate or an authorised manufacturer. It is not a licence to import and sell any product you like. Second, the BPO scope is broad and genuinely useful if you run a back-office or shared-services operation for a foreign group.

What It Takes to Qualify for a TISO

The conditions for a TISO are lighter than the manufacturing activities, but they’re specific, and one of them does most of the work. To win the promotion you’ll need to tick off a short list of requirements:

• THB10 million of annual spend. The real gate is spending, not capital: your selling and administrative expenses have to run at least THB10 million a year. It’s the BOI’s way of checking a TISO is a genuine operation with staff and premises, not a shell.
• Your activity fits the TISO scope. Your business plan has to fall inside one or more of the activities listed above: advisory work, sourcing information, technical services, BPO, or wholesale of Thai-made and affiliate goods. Anything outside that list isn’t a TISO.
• A credible business plan. You have to show a real operation with the staff and premises to back it, not a company set up just to hold a permit.
• Enough capital to fund it. A TISO has no fixed minimum capital of its own, but the BOI’s general baseline of THB1,000,000 per project applies, and new projects keep a debt-to-equity ratio of no more than 3:1. In practice you capitalise the company well enough to run the operation and support the work permits you want. We cover the numbers in our guide to BOI minimum capital.
• Foreign capital comes from abroad. A foreign-majority TISO has to remit its registered capital into the company’s Thai account from overseas, in the investor’s name, and show proof of it when the promotion certificate is issued.
• No machinery duty break. A TISO doesn’t get the import-duty exemption on machinery that other Group B activities keep. That rarely matters for a service business, but it’s written into the conditions.

The Honest Catch: No Tax Holiday

Here’s the part that gets glossed over. BOI sorts every promoted activity into groups that decide how much corporate income tax exemption you get. A TISO is a Group B activity. Group B gets no CIT holiday. None.

So if a setup firm waves “BOI tax benefits” at you for a trading business, be skeptical. Your TISO company pays corporate income tax at the standard 20% on its net profit, the same as any ordinary Thai company. The years-long tax exemption you may have read about belongs to the manufacturing and technology activities in Groups A1 through A4, not here. We break down the full ladder in our guide to BOI incentives.

There’s a second thing a TISO does not give you: the machinery import-duty exemption. Group B activities normally keep the duty perks, but the TISO conditions specifically strike out the machinery-duty exemption. That’s rarely a problem for a service business with no heavy equipment, but it’s worth knowing.

So why bother? Because the value of a TISO was never the tax. It’s the non-tax incentives, and for a foreign owner they’re the whole game:

• Up to 100% foreign ownership. Wholesale and most services are restricted for foreigners under the Foreign Business Act. BOI promotion is the mechanism that lets the Board approve majority or full foreign ownership in an eligible activity. See our guide on 100% foreign ownership for how that works.
• Work permits for your foreign staff. A BOI company brings in foreign experts under the Board’s own work-permit process, through the BOI’s one-stop service, instead of the ordinary immigration channel.
• You skip the standard staffing test. A normal Thai company sponsoring a foreign work permit needs THB2,000,000 in paid-up capital per foreigner and four Thai employees for every foreigner. A BOI company doesn’t play by that ratio. For a small trading or advisory team of foreigners, this is often the single biggest reason to go BOI.

Does E-Commerce Actually Qualify?

This is the question we get most, and the honest answer is: mostly no, and you should be careful with anyone who tells you otherwise.

Retail is not a promoted BOI activity. Even the digital-business activities in the BOI list explicitly exclude retail and wholesale of all product types. A TISO allows wholesale, and only the specific kinds we listed above: Thai-made goods, or machinery from your affiliate. Selling imported consumer products to the public through an online store is retail, and that falls outside what a TISO promotes.

Where an online business can sometimes fit is at the edges. If you’re running a genuine wholesale operation for Thai-manufactured goods, or a technology platform rather than a shop, or a BPO and support arm, there may be a promoted activity that suits you, whether that’s a TISO or something on the digital side. But “I want to run a Shopify store from Thailand and pay no tax” is not a BOI plan. If your model is truly e-commerce, treat its BOI eligibility as something to confirm case by case with a real look at your activities, not as a given. Our overview of which businesses qualify is the place to sanity-check where you might land.

How a TISO Compares to an IPO or IBC

A TISO isn’t the only support-and-trade structure BOI promotes. Two siblings sit right next to it in the professional-services category, and picking the right one matters. All three are Group B, so none of them carries a tax holiday. What differs is what you’re allowed to do and what you have to put in.

Structure	Best for	Headline condition	Tax
TISO (Trade and Investment Support Office)	Advisory, sourcing information, technical support, BPO, wholesale of Thai-made or affiliate goods	Annual selling and admin expenses at least THB10 million	Group B, no CIT holiday
IPO (International Procurement Office)	Sourcing and supplying raw materials and parts into manufacturing supply chains	Paid-up capital at least THB10 million; own or rent a warehouse with an IT inventory system	Group B, no CIT holiday
IBC (International Business Center)	A regional HQ managing and servicing affiliates: management, treasury, technical, trade	Paid-up capital at least THB10 million; at least 10 skilled staff	Group B on the BOI side, no CIT holiday

A quick way to choose: if you mainly provide services, advice, or support and do some wholesale of local or affiliated goods, a TISO fits. If your job is procuring parts and materials and feeding them to manufacturers, that’s an IPO, and you’ll need a real warehouse. If you’re centralising a multi-country group’s back office in Thailand, that’s an IBC.

One caveat on the IBC. Alongside the BOI promotion, Thailand’s Revenue Department runs a separate IBC tax regime with its own reduced rates and its own conditions. That tax package is not part of the BOI promotion, and its numbers are set by the Revenue Department, not the BOI. If a regional HQ is what you’re really after, treat the tax side as a separate conversation and get it verified for your specific setup before you rely on any figure.

How to Apply for a TISO

A TISO runs through the same BOI process as any other promotion, and for a service activity like this the review sits at the faster end. Here’s the shape of it:

1. Get your activity and numbers straight. Confirm your plan sits inside the TISO scope and shows how you’ll reach the THB10 million annual spend. This is where most of the real work is.
2. File the application online. You submit through the BOI’s e-service. A project up to THB200 million is reviewed in about 40 working days.
3. Attend the clarification meeting. A BOI officer walks through your plan with you, either at the BOI office or by video call. It runs about an hour.
4. Accept the promotion. Once you’re approved, you accept the offer within one month, then apply for the promotion certificate within six months.
5. Register the company and set up. With the certificate in hand you register your Thai company, remit your capital from abroad, and bring in work permits through the BOI’s one-stop service. Our step-by-step guide to registering a BOI company covers this stage.
6. Keep it running. You file a progress report each quarter and have to reach full operation within 36 months of the certificate.

We cover the whole process, timelines and documents included, in our guide on how to apply for BOI promotion.

Who Should Get a TISO

A TISO fits a specific profile: a foreign-owned business that lives on the trade-and-support side rather than manufacturing, and that needs to own itself and hire its own people more than it needs a tax break. It tends to suit:

• An overseas group that wants a Thai support, sourcing, or service arm it fully owns and staffs with its own people.
• A consultancy or technical-services business that would otherwise be blocked by the Foreign Business Act’s restrictions on foreign-owned services.
• A wholesaler of Thai-manufactured goods that needs full foreign ownership and foreign management on the ground.
• A back-office or shared-services operation running BPO for a foreign parent.

It’s a weaker fit if your whole case rested on a tax holiday, or if you’re a consumer retailer or a pure e-commerce shop. There, the comparison worth running is a promoted company against a plain Thai limited company, which we lay out in BOI company vs Thai limited company. Sometimes the plain company, plus a US Treaty of Amity structure or a different ownership route, is the better fit, and we’ll tell you when that’s the case.