Hatasakdi Na Pombejra Kititat Tungsuwan At present, international tax issues about the tax implications of certain satellite services provided by a satellite operator such as transponder services, internet connection services, and backhaul services concern whether earnings from such services should be regarded as service income/business profit or income from royalty for corporate income tax purpose. According to the recent discussion draft on tax treaty issues related to common telecommunication transactions by OECD (discussion draft), it can be deduced that, payment made by customers under typical "transponder leasing" agreements are made for the use of the transponder transmitting capacity and will not constitute royalties, but would therefore be in the nature of payments for services which constitute a business profit.
March 31 2010