Chirayuthchai TraisaengsatheanStrategic Finance for Property Development

Tax practice: selling a condominium with furniture

SBT 3.3% and VAT 7%, contract structure, tax point, the transfer-day procedure and controls when selling condominium units with furniture

Key takeaways

The condominium unit and freestanding furniture sit under different tax systems. The unit bears SBT of 3.3% on the day the transfer is registered, while the furniture bears VAT of 7% as soon as a tax point arises under Section 78, which is usually when payment is received before delivery. The reason for separating the contracts is the input VAT credit on the furniture and the correct treatment of each asset according to its nature, not to reduce the transfer fee or SBT.

Starting facts

The company develops projects for sale and is VAT-registered. It buys furniture into stock for resale to customers in the project and holds complete 7% input VAT tax invoices. It receives a furniture deposit in advance, which will be deducted from the price (T1), and then registers the transfer of the unit and delivers the furniture on the same day (T2).

Timing pointCondominium unitFurnitureAccounting and CIT
T1 Furniture deposit receivedNo SBT yetVAT arises immediately under Section 78(1)(b). Issue a tax invoice and include it in the PP 30 for that monthRevenue not yet recognised. Record a contract liability and output VAT
T2 Transfer registered and delivery madeSBT of 3.3% arises, paid at the land officeVAT only on the part of the price for which no invoice has yet been issuedRecognise revenue and cost for both items

Two frequent errors: (1) Input VAT on furniture bought for sale can be credited in the tax month of the invoice, without waiting for the sale date (Section 82/3), so it should not be parked in WIP. (2) VAT arises before accounting revenue, so a separate account for advances is needed, and PP 30 must be reconciled to revenue every month.

Two separate tax systems, determined by the nature of the asset

IssueCondominium unit or leasehold right (immovable property)Freestanding furniture (movable property)
DefinitionsCivil and Commercial Code (CCC) Section 139, including component parts under Section 144CCC Section 140
Output tax on freeholdSBT 3.3% (Section 91/2(6), Royal Decree No. 342)VAT 7% (Section 77/1)
Output tax on leaseholdVAT-exempt under Section 81(1)(ta) and outside the scope of SBTVAT 7% as well
Tax baseSale price or appraised value, whichever is higherContract price, which must be reasonable
Tax pointRegistration dateDelivery, transfer of ownership, receipt of payment or issue of an invoice, whichever occurs first
DocumentLand Department receipt and formFull-form tax invoice, Section 86/4
Related input VATNot creditable; included in costFully creditable
AccountInventory, WIP or cost of rental works, then transferred to costInventory: furniture, kept in a separate account, then transferred to cost of sales

Accounting must be controlled alongside tax: TFRS 15 paragraph 17 requires contracts with the same customer entered into at or near the same time to be combined, and the price to be allocated by standalone selling price. The accounting figures may therefore differ from the contract prices. The SBT and VAT bases still follow the contract price, but if the two figures differ greatly, the Revenue Department can use the difference as evidence to assess market price under Section 65 bis (4) and Section 79/3.

Comparing 3 contract structures

IssueSeparate contracts (recommended)Single combined pricePermanently fixed built-in
Output VATSBT on the unit and VAT on the furnitureSBT on the whole amountSBT on the whole amount, because it is a component part
Input VAT on furnitureFully creditableNot creditable; treated as costIncluded in WIP according to its nature
SBT baseCan fall only where the contract price of the unit is still higher than the appraised valueHighest baseHighest base
Transfer feeUnchanged, because it is calculated from the appraised valueUnchangedUnchanged
Documentation burdenHigh: 2 contracts, package list, tax invoiceLowMedium: BOQ as evidence
Tax riskLow where the price is reasonable and the documents are completeHigh: may face a retrospective VAT assessment with penalties and surchargesLow where it can be proved to be a genuine component part
ConclusionUse as the standardShould not be used unless the furniture value is very low and the loss of the credit is acceptedUse only for genuine built-in work

5 misunderstandings to correct before setting policy

  1. Separating the contracts reduces the transfer fee: not true. The 2% fee is based on the appraised value of the property, while the 1% WHT for a juristic-person seller (Section 69 ter) is based on the sale price or the appraised value, whichever is higher.
  2. Separating the contracts definitely reduces SBT: not true. SBT uses the higher base. If the appraised value equals or exceeds the contract price of the unit, the base does not fall at all.
  3. VAT on furniture arises on transfer day: not true. A down payment or instalment designated as payment for furniture gives rise to VAT as soon as it is received.
  4. Leasehold bears SBT like freehold: not true. The lease of immovable property is exempt from VAT under Section 81(1)(ta) and falls outside the scope of SBT.
  5. Furniture held for sale is a fixed asset: not true. It is inventory, is not depreciated and should not be on the asset register.

The measure reducing the transfer fee from 2% and the mortgage registration fee from 1% to 0.01% each takes effect under a Ministry of Interior notification published for the period 1 Jul 2026 to 30 Jun 2027. It applies to buyers who are Thai-national individuals, for residential property whose sale price and appraised value do not exceed THB 7 million. Check the full conditions before applying it to each unit.

The line between movable property and component parts

ItemClassificationOutput VATInput VAT
Sofas, beds, tables, chairs, freestanding cabinetsMovable propertyVAT 7%Creditable
TVs, refrigerators, washing machines and other removable electrical appliancesMovable propertyVAT 7%Creditable
Freestanding curtains, floor lamps, rugs, kitchenware, decorative itemsMovable propertyVAT 7%Creditable
Built-in cabinets and kitchens fixed to the permanent structureComponent partIncluded in the unit price, subject to SBTIncluded in WIP
Sanitary ware, taps, bathtubs, mirrors embedded in wallsComponent partIncluded in the unit price, subject to SBTIncluded in WIP
Wall-mounted or ceiling-concealed air conditioners, refrigerant pipes embedded in wallsComponent partIncluded in the unit price, subject to SBTIncluded in WIP
Recessed ceiling lights, permanently installed electrical and plumbing systemsComponent partIncluded in the unit price, subject to SBTIncluded in WIP
Ambiguous items, e.g. curtain tracks recessed in the ceiling, semi-freestanding cabinetsTax team decidesRecord the reasoning in a tax memoAccording to the decision

Can be removed without damaging the unit or the property itself = movable property (VAT). Cannot be removed without damage = component part (SBT).

Freehold and leasehold structures

Freehold + furniture sale

  • Recognise revenue on the unit when the transfer is registered, and on the furniture when it is delivered
  • Transfer fee of 2% of the appraised value; stamp duty is exempt because SBT is paid
  • WHT of 1% of the sale price or appraised value, whichever is higher, creditable against CIT
  • Input VAT on construction is included in WIP; input VAT on furniture is creditable

Leasehold + furniture sale

  • A lease is registered for no more than 30 years at a time, under CCC Section 540
  • Lease registration fee of 1% and stamp duty of 0.1% of the rent over the lease term
  • For rent received in advance under Revenue Department Directive No. Por. 73/1998, confirm the timing of tax recognition with the auditor
  • Do not write that the furniture is leased together with the unit, because leasing movable property bears 7% VAT and 5% WHT on every instalment. Use an outright sale contract instead

Consideration for the renewal period in a 30+30 structure is only a promise to lease, so it should be recognised separately when the renewal is actually registered, not averaged over 60 years from day one

WHT in leasehold depends on the lessee's status

Lessee (rent payer)Duty to withholdRate and formEffect on the lessor
Thai or foreign individualNone-Receives the full amount
Thai juristic personYes (Tor.Por. 4/1985)5%, PND 53Creditable against CIT; keep the Section 50 bis certificate
Foreign juristic person with a branch in Thailand and paying from ThailandYes5%, PND 53Same as a Thai juristic person
Foreign juristic person not carrying on business in Thailand, paying from abroadUsually none in practice-Record the reasoning in the file
Existing lessee assigns the leasehold rightConsider separatelyAccording to the nature of the incomeSeek the tax team's view before entering into the transaction

Tax point by payment instalment

PeriodCondominium unit: SBT 3.3%Furniture: VAT 7%
BookingNot yet arisenNot yet arisen, if stated as payment for the unit
Contract and down paymentNot yet arisenArises immediately if the payment is allocated to furniture
Instalments during constructionNot yet arisenEach instalment allocated to furniture gives rise to a tax point for that instalment
Transfer notice and unit inspectionNot yet arisenNot yet arisen, if the furniture payment has not been received
Transfer and delivery dayArises; paid at the land officeVAT on the remainder; issue a tax invoice

The simplest approach is to have the furniture paid in a single instalment on transfer and delivery day. If the business must receive furniture payments during the instalment period, issue a tax invoice on the date of each receipt.

Instalment payments with furniture

Example: THB 100,000 per instalment

ItemTHBTreatment
Unit instalment70,000.00SBT receipt, paid on transfer day
Furniture payment, VAT base (25,000 ÷ 1.07)23,364.49Tax invoice
VAT 7%1,635.51PP 30 for that month
Instalment interest5,000.00Confirm the tax status first (see note)
Total100,000.00

The tax invoice must cover only the furniture portion. Issuing an invoice covering the whole amount results in VAT being charged on the unit price without any entitlement to do so. Issue a single "tax invoice/receipt" document that can be divided into zones, with the VAT-base portion separate from the items outside the VAT base.

Note on interest: Do not assume that interest on instalments is automatically VAT-exempt. The part arising from the furniture sale may relate to the value of the goods under Section 79. Confirm with the tax adviser and state in the contract separate interest for the unit portion and the furniture portion. The approach that removes the most issues is to charge no interest on the furniture price.

Timing across different years: payment received in Y1, purchase in Y2, delivery in Y3

Example: 3 instalments of THB 25,000 each, including VAT

YearEventOutput VATInput VATNet
Y1Receipt, base 70,093.474,906.530.00Payable 4,906.53
Y2Furniture purchase 45,0000.003,150.00Credit 3,150.00
Y3Delivery: do not issue VAT again0.000.000.00
Total4,906.533,150.001,756.53

In Y3, revenue recognised is THB 70,093.47, cost of sales THB 45,000.00 and gross profit THB 25,093.47. Net VAT of THB 1,756.53 is close to 7% of gross profit, which reflects the principle of taxing value added.

The company pays VAT up front, before it has any revenue and before it has bought the goods, so set the tax money aside in a separate account. Before transferring unsold furniture stock to cost, test NRV under TAS 2 and apply FIFO or weighted average consistently. LIFO is not permitted.

Procedure from D-30 to after transfer day

  1. D-30 Set the structure: confirm freehold or leasehold, draft two separate contracts, set the price from the BOQ plus a normal margin, and have the tax team approve the price split.
  2. D-14 Check the items: finalise the Furniture Package List per unit, count the actual items, remove built-in items from the list, and have the customer sign.
  3. D-3 Prepare documents: draft the tax invoice, compare the appraised value with the sale price, and prepare the unit receipt and power of attorney.
  4. Transfer day: register the transfer, pay SBT, fees and 1% WHT, deliver the furniture with a delivery note, and issue the tax invoice on the same day if one has not already been issued for advance payments.
  5. After transfer day: file PP 30 by the 15th of the following month, or the extended date for e-Filing under the latest announcement. Keep the SBT receipt and record the cost transfer.

The tax invoice must always match the tax point. If payment is received in advance, issue the invoice on the date of receipt, and never issue one in advance before a tax point has arisen.

Accounting entries

EventDebitCredit
Purchase furniture into stockInventory – furniture (excluding VAT), input VATPayables
Construction cost and built-in itemsWIP (including non-creditable input VAT)Payables
Receive booking deposit or down payment for the unitCashContract liability – unit price
Receive advance payment for furnitureCashContract liability – furniture, output VAT
Transfer day: recognise unit revenueContract liability – unit price, cash or receivablesRevenue from sale of condominium units
Transfer day: seller's taxes and feesExpenses: SBT, transfer fee, withholding tax (WHT) deductedCash
Transfer day: recognise furniture revenueContract liability – furniture, cash or receivablesRevenue from furniture sales, remaining output VAT
Transfer costCost of sales – condominium units, cost of sales – furnitureWIP, inventory – furniture

Leasehold: record advance rent as deferred income and recognise it gradually, only over the registered period. If the arrangement is a finance lease or an operating lease under TFRS 16, set the cost matching according to the classification result and confirm it with the auditor.

Common input VAT shared between the VAT and SBT businesses must be apportioned under Section 82/6 and the Director-General's Notification on VAT No. 29. See the section on input VAT apportionment for details.

Risks and control measures

RiskLevelMeasures
Retroactive VAT assessment on furniture, with a penalty under Section 89 and a surcharge of 1.5% per month under Section 89/1, capped at the amount of tax.HighSeparate the contracts in every deal and do not state "fully furnished" in the unit contract.
Furniture priced abnormally low or high.HighRefer to the BOQ plus a normal margin, and have the tax team approve before the contract is issued.
Forgetting to issue a tax invoice at the tax point of an instalment payment.HighTake payment in a single instalment on transfer day, or link a trigger in the receivables system.
Furniture input VAT mixed into WIP cannot be separated retroactively.HighKeep separate accounts for furniture inventory, creditable input VAT, input VAT awaiting apportionment, and non-creditable input VAT.
Furniture held for sale appears in the asset register.MediumReview the register quarterly.
Incorrect apportionment of common input VAT.MediumKeep a working paper every month and review the criteria used.
Leasehold: WHT withheld in the wrong cases, or income spread beyond the registered period.MediumCheck the tenant's status in every deal.

Example of the effect of failing to remit output VAT

Output VAT unremitted for 3 periods totals THB 4,906.53 and is discovered after 10 months. Tax 4,906.53 + penalty of 1x 4,906.53 + surcharge at 1.5% × 10 months 735.98 = THB 10,549.04. If no tax invoice was issued, separate penalties and sanctions may also apply. Forgetting to claim input VAT carries no penalty, but it costs you money: if THB 3,150 of input VAT becomes a cost, it saves only THB 630 of CIT, a net loss of THB 2,520.

Customer cancellation: if the money is refunded to the customer, issue a credit note in accordance with the rules. If the money is forfeited and not refunded, consider whether there are grounds to reduce output VAT. Do not issue credit notes automatically.

Defence File per deal

  • Condominium unit sale and purchase agreement or registered lease, plus a separate furniture sale agreement
  • Furniture Package List stating the items and price per piece, signed by both parties
  • Delivery note, copy of the tax invoice, and receipts for SBT and the transfer fee
  • WHT certificate: 1% for freehold or 5% for leasehold, when the tenant is a juristic person
  • BOQ and furniture pricing method; a table separating built-in items from loose items per unit
  • Monthly input VAT apportionment working paper
  • Tenant status record and rental income recognition schedule
  • Output tax invoice register reconciled to PP 30. Keep documents for at least 5 years.

30 / 60 / 90-day action plan

StageAction requiredOutcome
30 daysIssue the contract separation policy and a furniture sale agreement template, open separate accounts, and prepare a Package List for stock not yet transferred.Signing policy and chart of accounts in actual use
60 daysSeparate built-in items, move furniture held for sale out of the asset register, choose the input VAT apportionment method, and train the sales and transfer teams.Clean register; the team knows the tax point
90 daysRehearse the transfer day procedure for one unit, and assemble a retrospective Defence File for deals already transferred.Updated checklist and audit-ready file