Eight Koh Phangan companies now face land disposal orders

The 112 cases are at different legal stages

Thailand's Interior Ministry said officials reviewed records for 1,832 juristic persons holding land on Koh Phangan. They identified 112 entities whose foreign shareholding data appeared to exceed the threshold permitted under the land rules and therefore required further examination. Together, those entities hold 124 plots covering about 86 rai, 3 ngan and 42.4 square wah.

The headline number does not describe 112 completed enforcement cases. Of the 112 entities, 104 were newly identified for follow-up and eight were cases in which court judgments had already been issued. As of 25 August, the Surat Thani governor had issued land disposal orders to eight entities covering nine plots. Another 28 cases were being considered for disposal orders, while the Koh Phangan Land Office branch was still compiling material on 76 more.

That distinction matters for anyone assessing a company that holds land on the island. Being included in the 112-company review group is not the same as a finding that the company acted unlawfully, and it is not the same as a disposal order. The eight entities already ordered to dispose of land are at a materially later stage. On 10 September, a Thai government update again referred to eight entities and nine plots, with the remaining cases still proceeding through the legal process.

Why company-held land now deserves closer scrutiny

Thailand's Land Code places separate limits on land rights for certain juristic persons. Among other tests, a limited or public limited company can be treated as an alien for land purposes if foreigners hold more than 49% of its registered capital or if foreign shareholders make up more than half of all shareholders. The code also provides a disposal mechanism for land acquired unlawfully or without the required permission, with the period for disposal set by the competent authority within the statutory range.

This does not mean that every Thai company with foreign shareholders is unlawful or that every company-owned villa is affected by the Koh Phangan cases. The relevant question is whether the specific ownership structure, funding, shareholder position and actual control comply with the legal basis on which the company holds land.

For a buyer, that makes the corporate wrapper part of the property due diligence rather than a paperwork detail. The land title, shareholder and director history, source of acquisition funds and the company's legal basis for retaining the land can all matter. The Koh Phangan orders show that enforcement can move beyond data screening and document requests to a requirement that a specific landholding be disposed of.

What the official figures do not prove

The government has not said that all 112 entities committed nominee offences or other violations. Its own breakdown separates newly flagged cases, cases with court judgments, cases awaiting consideration and the eight entities already subject to disposal orders. Treating all 112 as proven offenders would therefore go beyond the published evidence.

The position of one company also cannot be assumed from another company's case. A current owner or prospective buyer needs the documents and facts for the specific entity and plot. Where land is being acquired through, or together with, a company, the individual legal position should be checked with a qualified Thai lawyer and, where appropriate, the relevant Land Office before a substantial payment is committed.