Registered at one address but operating from another — do you need to register a branch?

When your registered address doesn't match where you actually do business, which agencies do you need to notify, in what order, and what obligations come with using rented space?

Many businesses initially register their company or partnership at one address — often the owner's home — but once operations actually begin, they rent an office, open a storefront, or set up a warehouse somewhere else. Many owners treat this as a minor detail, but under the law, the address where you actually operate the business is something you are required to report to the relevant government agencies.

What counts as a place of business

A place of business (สถานประกอบการ) refers to any location used to regularly carry on business activities — whether that's a head office, a branch, a warehouse, a factory, or even a production site. If your business operates from more than one location, whether that's the address originally registered or a new address you've just started using, the law treats each one as a separate "place of business" that must be registered individually.

Do you need to register a branch?

The answer is yes, if the place where you actually operate doesn't match your registered address, and you need to follow these steps in order:

1. The Department of Business Development (DBD) — must be done first, regardless of whether you are VAT-registered

Every company (private limited company or limited partnership) that opens an additional place of business or changes its location must first notify the Department of Business Development (DBD) of the amendment, so that the company's registration data matches reality. This step is required for every business, whether or not it is registered for VAT (ภาษีมูลค่าเพิ่ม).

2. The Revenue Department (only for businesses already registered for VAT)

If your business is already registered for VAT, under Section 85/7 of the Revenue Code you must notify the Revenue Department of the change to your VAT registration at least 15 days before the additional place of business opens, in order to obtain a VAT registration certificate specific to that location, by filing form PP 09 (ภ.พ.09) together with supporting documents. This step is tied only to VAT-registered status — if you are not yet VAT-registered, you do not need to notify the Revenue Department on this point. Filing late may result in a penalty at the discretion of the officer.

If you're using rented space that isn't your own, what else do you need to prepare?

If the new place of business is rented rather than owned by the company, there are additional documents and tax obligations to prepare, covering both registration paperwork and taxation, as follows:

Documents required for registration

Both the DBD and the Revenue Department require documents proving your right to use the premises: a copy of the lease agreement, a letter of consent to use the premises from the building owner, together with a copy of the ID card and house registration of the property owner or lessor, and photographs of the place of business clearly showing the business signage and house number.

Tax obligations arising from renting

Withholding tax on rent If the business is a company (a private limited company or partnership), it must withhold tax at 5% from the rent paid to the lessor every time rent is paid, remit it to the Revenue Department, and issue a withholding tax certificate for the lessor to keep as proof.
Stamp duty A lease agreement for immovable property is subject to stamp duty at a rate of 1 baht per 1,000 baht of the lease value. Unless the contract states otherwise, the law requires the lessor to bear the stamp duty, and the lessee to cancel the stamp.

Example: If a business rents space for 20,000 baht per month, it must withhold 5% tax, or 1,000 baht, paying the lessor a net amount of 19,000 baht, then remitting the 1,000 baht withheld to the Revenue Department along with issuing a withholding tax certificate (form 50 Tawi) for the lessor to keep and use as their own tax credit.

Why this matters

Many people think that as long as the business is operating somewhere, there's no need to notify anyone. But failing to register a branch properly can lead to the following consequences:

Company information doesn't match reality Because the DBD hasn't been notified, the address on the company's registration certificate won't match where the business actually operates. This can create problems when banks or business partners ask to verify company information.
Tax invoices issued may not comply with the law for businesses already registered for VAT, because under Section 86/4 a tax invoice must state the address and status — "head office" or "branch no. ..." — matching the place of business registered with the Revenue Department. If issued from an unregistered location, the tax invoice may be considered incomplete.
Risk of audit If an officer discovers that the business is actually operating from a location that doesn't match either agency's registration, it may be called in for an explanation or face legal action.
Forgetting to withhold tax on rent If you use rented premises but fail to withhold tax correctly, the rent expense may not be fully deductible as a business expense.

A worked example

ABC Company Limited registered its head office at a director's home in one province, and had already registered for VAT. The company later rented a shophouse in another province to open an actual storefront selling products, but the owner thought of it as just an "extra sales point," not a big deal, and so did not register it as a branch with either the DBD or the Revenue Department.

Once the company began operating from this storefront without registering it as a branch, the following consequences arose:

The company's registration certificate no longer matched reality, because it still showed only the head office address, even though the company was genuinely operating a storefront in another province. If a bank or business partner asked to verify the company's information, they might question why the actual sales location doesn't appear in the registration.
Tax invoices issued from the storefront were not legally complete, because every tax invoice issued from this storefront still had to state the "head office" address on file with the Revenue Department, even though the company was actually selling from a different location that didn't match its registered place of business.
Customers might not be able to use the tax invoices to claim input tax credits, because the address on the tax invoice didn't match the place of business registered with the Revenue Department, putting the documents at risk of being challenged.
Risk of audit and penalties If the Revenue Department discovers that the company is operating from an unregistered location, it may be called in for an explanation and face penalties for filing the change notification late.

The correct approach would have been for ABC Company Limited to register the new branch with the DBD before opening the storefront, then notify the Revenue Department to obtain a VAT registration for this storefront specifically, at least 15 days before the actual opening date, so that all tax invoices and documents issued from this storefront would be legally valid.

Summary

Operating from a location different from your registered address is not something you can afford to overlook. The law clearly requires you to register any additional place of business, starting with the Department of Business Development every time, regardless of whether you are VAT-registered, and if you are VAT-registered, followed by notifying the Revenue Department at least 15 days before the additional place of business opens. If that space is rented, you also need to prepare complete documentation proving your right to use it, and remember to withhold tax on rent correctly as required by law. If your business is about to start operating from a new location, plan ahead and consult an accounting and legal professional to make sure everything is done correctly from the start.