Quick answer: Thai companies must register for GST in India before making any taxable supply — via NRTP registration (Form GST REG-09, valid 90 days, extendable once for another 90 days) if they lack an Indian entity, or regular registration (GSTIN allotted in 3-7 working days) if they operate through a subsidiary or branch. Because the Hague Apostille Convention does not enter into force for Thailand until 28 February 2027, documents currently require embassy attestation, adding 10-15 business days and stretching the overall timeline to 4-6 weeks. Neither the India-Thailand DTAA's 10% withholding rates nor AIFTA's tariff concessions reduce GST obligations, since GST is a separate indirect tax.
Key takeaways:
- GST registration for Thai companies takes 4-6 weeks end-to-end, longer than apostille countries.
- Embassy attestation of Thai documents takes 10-15 business days, versus 3-5 for apostille.
- NRTP registration is valid 90 days, extendable once for another 90 days.
- Regular GST registration is allotted within 3-7 working days via an Indian entity.
- India-Thailand DTAA sets 10% withholding on dividends, interest, and royalties (no separate FTS article) — GST is separate.
GST Registration for Thai Companies in India
India and Thailand share a growing economic partnership, with bilateral trade reaching approximately US $19 billion in FY25. In April 2025, the two countries elevated ties to a Strategic Partnership, pledging to realize the full potential of economic cooperation. Thailand occupies the 27th position in foreign direct investment (FDI) equity inflows into India, with cumulative FDI of US $1.47 billion from April 2000 to March 2025. Major Thai companies including Indorama Ventures, Srithai Superware, Thai Summit Group, CP Group, and SCG Chemicals have established operations in India across petrochemicals, automotive components, food processing, real estate, and infrastructure.
For every Thai company conducting taxable business in India — whether through a Wholly Owned Subsidiary (WOS), Branch Office, Liaison Office, or project-based engagement — obtaining GST registration is a mandatory prerequisite before making taxable supplies. Unlike domestic Indian businesses that enjoy turnover-based exemptions (INR 40 lakh for goods, INR 20 lakh for services), foreign entities from Thailand are generally required to register for GST regardless of revenue.
This guide covers the complete GST registration process for Thai companies, including how the India-Thailand DTAA and AIFTA interact with GST, the specific documents required from the Department of Business Development (DBD), timelines, costs, and compliance challenges unique to Thai businesses operating in India.
How Thailand's DTAA Affects GST Registration
The India-Thailand DTAA, signed on 29 June 2015 and effective in India from 1 April 2016, governs the taxation of cross-border income between the two countries. It provides standardized withholding tax rates at 10% across most categories, consistent with India's ASEAN treaty practice.
However, the DTAA applies exclusively to direct taxes (income tax, corporate tax). GST, being an indirect consumption tax, falls entirely outside the treaty's scope. Thai companies cannot use DTAA provisions to reduce or defer their Indian GST liability.
Key DTAA Rates (Income Tax Only)
- Dividends (Article 10): 10% withholding — lower than India's domestic rate of 20%
- Interest (Article 11): 10% withholding on interest payments between the two countries
- Royalties (Article 12): 10% withholding on royalty and technology licensing payments
- Fees for Technical Services (FTS): The India-Thailand DTAA has no separate FTS article — FTS payments fall under domestic law (s.115A, 20% withholding) or, where the Thai provider has a PE in India, the Article 7 business-profits article
- Permanent Establishment (PE): A fixed place of business, building site exceeding 183 days, or dependent agent in India can create a PE for the Thai entity, triggering full income tax and mandatory GST registration
To claim these DTAA benefits, Thai companies must obtain a Tax Residency Certificate from the Thai Revenue Department and file Form 10F with Indian tax authorities. These DTAA benefits apply to direct tax only — GST obligations exist independently.
AIFTA and Market Access
The ASEAN-India Free Trade Agreement (AIFTA), effective since 2010, provides preferential tariff rates on goods traded between Thailand and India. While AIFTA reduces customs duties on many imports, it does not modify domestic GST rates or registration requirements. GST compliance in India remains governed entirely by the CGST and SGST Acts.
Document Requirements from Thailand
Thailand deposited its instrument of accession to the Hague Apostille Convention on 30 June 2026, but the Convention enters into force for Thailand only on 28 February 2027. Until then, Thai documents must undergo embassy attestation (consular legalization) to be accepted in India. This process is more time-consuming than apostille but is well-established for India-Thailand transactions.
Documents Required
- DBD (Department of Business Development) Certificate — Company registration certificate or affidavit of registration from the Thai Ministry of Commerce (embassy-attested)
- Company Registration Number — Thai corporate identification number
- Board Resolution authorizing GST registration in India (notarized and embassy-attested)
- Passport and Indian business visa of the authorized signatory
- PAN card of the authorized signatory or Indian entity
- Proof of Indian business address — rental agreement, utility bill, or property tax receipt
- Indian bank account details — cancelled cheque or recent bank statement
- Photographs of the authorized signatory
- Tax Residency Certificate (TRC) from the Thai Revenue Department — required for DTAA benefits, often requested as supporting documentation
Embassy Attestation Process for Thai Documents
Until the Apostille Convention enters into force for Thailand on 28 February 2027, the attestation process involves: (1) notarization by a Thai notary public, (2) authentication by the Thai Ministry of Foreign Affairs (MFA), and (3) attestation by the Indian Embassy or Consulate in Bangkok. This process typically takes 10-15 business days. Once the Convention is in force for Thailand, the process is expected to be simplified to a single apostille certification. For a comparison of methods, see Apostille vs. Embassy Attestation.
Step-by-Step GST Registration Process
Option A: NRTP Registration (No Indian Entity)
If a Thai company wants to make taxable supplies in India without establishing a permanent entity, it can register as a Non-Resident Taxable Person (NRTP):
- Apply at least 5 days before starting business — Submit Form GST REG-09 on the GST portal
- Appoint an authorized signatory — Must be a resident Indian with a valid PAN and Indian mobile number
- Submit embassy-attested DBD documents — Company registration certificate, board resolution, signatory passport
- Pay the mandatory advance deposit — Amount equal to estimated GST liability for the 90-day registration period
- Receive Temporary Reference Number (TRN) — Generated automatically after payment confirmation
- Complete Part B — Upload supporting documents, provide Indian address, sign with DSC
- GSTIN issued — Valid for 90 days, extendable once for another 90 days
Option B: Regular Registration (Via Indian Subsidiary or Branch)
- Establish the Indian entity — Obtain Certificate of Incorporation and PAN from MCA
- Access the GST portal — Navigate to Services, then Registration, then New Registration
- Complete Part A — Enter PAN, email, and mobile number for OTP verification
- Complete Part B — Business details, principal place of business, bank account, authorized signatory
- Upload documents — PAN, address proof, MoA, board resolution, DBD certificate
- Submit with DSC — Digital Signature Certificate is mandatory for companies
- GSTIN allotted in 3-7 working days — Under GST 2.0, auto-approval can process applications in 3 days
Timeline and Costs for Thai Companies
Timeline Breakdown
| Step | Duration |
|---|---|
| Thai document attestation (embassy route) | 10-15 business days |
| Indian PAN application (if needed) | 7-15 business days |
| GST application preparation | 2-3 business days |
| GST portal processing | 3-7 working days |
| Total estimated timeline | 4-6 weeks |
Cost Breakdown
| Item | Approximate Cost |
|---|---|
| Government GST registration fee | INR 0 (free) |
| Embassy attestation charges | THB 1,000-3,000 per document |
| Notarization in Thailand | THB 500-2,000 per document |
| Professional/CA fees in India | INR 5,000-15,000 |
| NRTP advance deposit | Equivalent to estimated GST liability |
| DSC procurement | INR 1,500-3,000 |
Common Challenges for Thai Companies
1. Thailand's VAT vs India's GST — Different Structures
Thailand operates a single-rate VAT system at 7% (reduced from the statutory 10% by successive royal decrees). India's GST uses a multi-slab structure (5%, 18%, and a 40% demerit rate, following the GST 2.0 rate rationalisation effective 22 September 2025) with the split between CGST, SGST, and IGST, monthly filing requirements, e-invoicing mandates, and complex input tax credit reconciliation. Thai companies accustomed to their simpler single-rate VAT system must adapt to India's significantly more complex GST framework with multiple returns, rate classifications, and state-wise registrations.
2. Embassy Attestation Delays (Transitioning to Apostille)
Thailand acceded to the Hague Apostille Convention on 30 June 2026, but the Convention enters into force for Thailand only on 28 February 2027, so Thai companies must currently undergo embassy attestation through the Indian Embassy in Bangkok. This adds 10-15 business days compared to 3-5 days for apostille countries. Companies should plan document authentication well in advance. Once the Convention is in force for Thailand, the process is expected to be simplified significantly.
3. AIFTA Tariff Concessions vs GST Obligations
Some Thai companies incorrectly assume that AIFTA tariff concessions extend to GST exemptions. AIFTA reduces customs duties on qualifying goods traded between ASEAN members and India but has no impact on domestic GST rates or registration obligations. IGST on imports is charged separately at the point of clearance, regardless of any preferential tariff rate under AIFTA.
4. Multiple GSTIN Requirements Across States
If a Thai company operates across multiple Indian states — common for infrastructure and automotive component suppliers with facilities in different regions — a separate GSTIN is required for each state. Each state registration demands its own monthly GSTR-1/3B filing, multiplying the compliance burden significantly.
5. Baht-Rupee Currency Fluctuation and Valuation
The Thai Baht-Indian Rupee exchange rate directly affects the GST-assessable value of imported goods and intercompany transactions. Indian customs uses the exchange rate notified by the CBIC (Central Board of Indirect Taxes and Customs) on the date of filing the Bill of Entry, which may differ from the commercial exchange rate used in invoicing. Thai companies must reconcile these valuation differences carefully to avoid GST underpayment or overpayment issues.
Why Choose Beacon Filing
Beacon Filing has strong experience supporting Thai companies operating in the India-Thailand business corridor. We handle everything from embassy attestation coordination through the Indian Embassy in Bangkok to GST portal submission, ongoing GST return filing, and FEMA/RBI compliance. Our services also include transfer pricing documentation and annual compliance management. Visit our Thailand country page for more on establishing operations in India from Thailand.