Nominee companies crackdown in Chonburi

Received this email this morning

News Details: "Foreigners Own Thai Land via 36,277 Companies; Chonburi Ranks #1, Authorities Eyeing Nominees"

1. Overview and Background of the Investigation

Database Integration: The Department of Business Development, in collaboration with the Department of Land, linked and cross-checked their real estate

 ownership databases.

Total Discovered: They found 36,277 legal entities with foreign co-investors holding land title deeds across Thailand.
Target Group: Authorities have categorized all 36,277 entities as high-risk target groups for in-depth investigation to prevent and suppress the illegal use of Thai nominees holding land on behalf of foreigners.

2. Shareholding Structure Breakdown
Based on the shareholding structures of these 36,277 legal entities, they are divided into two main categories:
Group with foreign shareholding up to 49% (Total: 31,516 entities):
Limited Companies: 30,633
Public Limited Companies: 737
Partnerships: 146

Note: This group is considered high risk and is being closely examined regarding their source of funds and the actual Thai shareholders.

Group with foreign shareholding of 49% or more (Total: 4,761 entities):
Limited Companies: 4,709
Public Limited Companies: 41
Partnerships: 11

Note: Most entities in this group legally operate under investment incentives, such as those from the BOI or the Industrial Estate Authority of Thailand (IEAT) within the Eastern Economic Corridor (EEC).

3. Land Title Deed Ownership Breakdow
Focusing on the group with foreign shareholding up to 49% (31,516 entities), the details of land ownership are as follows:

By Number of Plots Owned:
Holding 1 plot: 20,537 entities
Holding 2–5 plots: 8,068 entities
Holding 6–10 plots: 1,511 entities
Holding 11 plots or more: 1,400 entities

By Total Land Area Owned:

Up to 1 Rai (~1,600 sq.m.): 21,106 entities
Over 1 Rai up to 2 Rai: 2,550 entities
Over 2 Rai up to 5 Rai: 2,490 entities
Over 5 Rai up to 10 Rai: 1,505 entities
Over 10 Rai (~16,000+ sq.m.): 3,865 entities

4. Geographical Concentration & Top Provinces
Land ownership is heavily concentrated in 16 strategic provinces (Bangkok, its perimeter, and major tourist cities), accounting for 35,154 entities (over 96.9% of the total):
Rank 1: Chonburi Province (11,215 entities)
Rank 2: Surat Thani Province (5,752 entities - including Koh Samui)
Rank 3: Bangkok (4,437 entities)
Rank 4: Phuket Province (3,086 entities)

5. Legal Penalties and Next Steps
Nominee Penalties: If an investigation reveals the illegal use of nominees to hold land, offenders face penalties under the Foreign Business Act:
Imprisonment: Up to 3 years
Fines: From 100,000 to 1,000,000 THB, or both
Property Enforcement: Forced disposal/sale of the real estate

Next Phase: Government agencies are also preparing to expand their investigations to include condominium ownership.