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6.3 Organizations That Operate for Profit or Revenue Sharing
               Limited companies, public limited companies, and partnerships are profit-driven, revenue-sharing

               entities  widely  recognized  in  the  business  sector.  This  section  focuses  specifically  on  the  tax
               benefits  and  regulatory  provisions  available  to  companies  or  partnerships  that  engage  in
               Corporate Social Responsibility (CSR) activities.

               1.  General CSR Expenses Eligible for a 1x Tax Deduction, Up to 2% of Net Profit

               A legal partnership or company may deduct CSR-related expenses under Section 65 Ter (3)  139  of
               the Revenue Code at the actual amount paid, but not exceeding 2% of net profit. The deductible
               categories include:

               (1) Expenses for public charity or public benefit as specified by the Director-General with the

               approval of the Minister, deductible up to 2% of net profit; and
               (2) Expenses for education or sports as specified by the Director-General with the approval of the
               Minister, also deductible up to 2% of net profit.

               Examples of charitable expenses eligible for tax deductions include donations to the Thai Red
               Cross Society, temples, government hospitals or schools, public libraries, museums, government
               art galleries, the Elderly Fund, private rehabilitation centers for children, the elderly, or persons
               with disabilities that operate free of charge 140 , funding for public rehabilitation centers, and other
               charitable  organizations,  hospitals,  or  educational  institutions  designated  by  the  Minister  of

               Finance and announced in the Government Gazette.

               Examples of public benefit expenses eligible for tax deductions include donations to the Disability
               Rehabilitation Fund under the Rehabilitation of Persons with Disabilities Act, the Social Welfare
               Promotion Fund under the Social Welfare Promotion Act, the Child Protection Fund under the
               Child  Protection  Act,  or  the  National  Sports  Development  Fund  established  by  the  Cabinet
               resolution on February 16, 1999 141 .






               139  Section 65 Ter of the Revenue Code specifies items that are prohibited from being treated as expenses in the
               calculation of net profit. Section 65 Ter (3) prohibits expenses of a personal nature, gratuities, or charitable donations.
               However, exceptions are provided: “Expenses for public charity or public benefit, as prescribed by the Director-
               General with the approval of the Minister, may be deducted up to 2 percent of net profit; and expenses for education
               or sports, as prescribed by the Director-General with the approval of the Minister, may also be deducted up to an
               additional 2 percent of net profit.”
               140  Notification of the Ministry of Finance on Income Tax and Value Added Tax (No. 2) regarding the Specification of
               Organizations, Charitable Institutions, Hospitals, and Educational Institutions under Section 47 (7) (b) of the Revenue
               Code, announced on October 12, B.E. 2535 (1992).
               141  Royal Decree issued under the Revenue Code on Tax Exemption (No. 428), B.E. 2548 (2005), given on January 8,
               2005.
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