If the company has not started trading and has no income, does it still need bookkeeping, tax filings and an audit?
A common situation: the company is registered, but the factory is still being built and BOI is still under review, so there is no income for months or even a year or two. Many companies assume "no business, no books" — and only discover the gap in filings when they want to start operations, apply for BOI or take a bank loan.
1. What still has to be done with no income
| Item | Why it still applies |
|---|
| Bookkeeping | Capital received, start-up costs, rent and salaries all have to be recorded |
| Monthly PP.30 VAT return | VAT-registered companies must file even with no sales — a nil return; input VAT can be carried forward |
| Monthly withholding tax returns | Any service fees, rent or salaries paid require withholding and filing |
| Annual audit and shareholders' meeting | A limited company's annual financial statements must be audited by a Thai CPA, regardless of income |
| Filing financial statements with the DBD | Within 1 month of the shareholders' meeting |
| PND.50 annual CIT return | Required even with a loss; losses can be carried forward for 5 years against future profits |
2. Consequences of not filing
Surcharges of 1.5% per month on tax due, plus penalties;
Late filing of financial statements can lead to penalties for the company and its directors from the DBD;
Gaps in the record affect BOI applications, bank accounts or loans, work permits and anything else that requires financial statements;
Companies that fail to file for a long time may be flagged by the DBD and even struck off.
3. The easiest approach during set-up
During set-up there are few transactions and little bookkeeping. Keeping monthly books and filings makes the year-end audit quick. Treat start-up costs, trial production costs and input VAT on machinery correctly under BOI and tax rules from the start, so there is nothing to redo after launch.
4. Basis and scope of service
Basis: Thai Accounting Act on bookkeeping and financial statements; Civil and Commercial Code on annual audits and shareholders' meetings of limited companies; Revenue Code on VAT, withholding tax and CIT filing and loss carry-forward; DBD rules on filing financial statements. Penalties are determined by the authorities.
Related services: Accounting & Tax Outsourcing | Audit Services
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