An Asia business glossary is a working reference to the local terms, licenses, and government bodies that come up when a foreign investor registers a company, applies for a work visa, or files taxes in an Asian market. Unlike a general finance dictionary, this one sticks to the words that actually appear on your incorporation certificate, your visa stamp, and your tax filing, across the ten markets InvestinAsia supports.
The confusing part is not that these concepts are hard. It’s that every country names them differently. A foreign-owned limited company is a PT PMA in Indonesia, a Sdn Bhd in Malaysia, a Pte Ltd in Singapore, and a WFOE in China. Compare two markets side by side using their official documents, and you will spend more time decoding vocabulary than evaluating the actual business case. This glossary exists to fix that.
Key Takeaways
- Entity names differ sharply by country. A PT PMA (Indonesia), Sdn Bhd (Malaysia), Pte Ltd (Singapore), and WFOE (China) all describe a foreign-owned limited company, but using the wrong term with a bank or regulator causes real delays.
- Foreign ownership caps vary widely: Thailand defaults to 49% under the Foreign Business Act unless you secure BOI promotion or another exemption, while Indonesia’s Positive Investment List and Singapore both allow 100% foreign ownership in most sectors.
- A registration certificate is not a work permit. Directors and shareholders still need a separate visa, such as Indonesia’s KITAS or Singapore’s Employment Pass, to legally work in the business they own.
- Vietnam changed its licensing order in 2026. Under the Law on Investment 2025, some investors can now obtain the Enterprise Registration Certificate before the Investment Registration Certificate, reversing the sequence that applied for years.
Business Entity Terms Show Up Across Asian Markets
Business entity terms describe the legal structure a foreign investor registers to operate commercially in a given country. Almost every Asian market requires foreign investors to set up a distinct legal entity before they can hire staff, sign contracts, or issue invoices, and each country has its own name and rulebook for that entity.
PT PMA (Indonesia)
A PT PMA, short for Perseroan Terbatas Penanaman Modal Asing, is Indonesia’s foreign-owned limited liability company structure, established under the Company Law (No. 40 of 2007) and Indonesia’s Positive Investment List. Most sectors allow up to 100% foreign ownership, though some, such as domestic courier services or certain media categories, cap foreign equity at 49%, 51%, or 67% depending on the activity. A PT PMA needs at least two shareholders and generally a minimum investment plan around IDR 10 billion. For a full walkthrough of the structure and paperwork, InvestinAsia’s PT PMA registration service covers shareholder setup and licensing end to end.
Sdn Bhd (Malaysia)
Sdn Bhd stands for Sendirian Berhad, Malay for “private” and “limited.” It is Malaysia’s private limited company structure, registered with the Companies Commission of Malaysia (SSM) under the Companies Act 2016. Most sectors permit full foreign ownership, but every Sdn Bhd, regardless of shareholder nationality, needs at least one director who ordinarily resides in Malaysia. InvestinAsia’s complete guide to Sdn Bhd registration breaks down that resident director requirement and how founders typically satisfy it.
Pte Ltd (Singapore)
Pte Ltd, short for Private Limited, is Singapore’s standard company structure under the Companies Act, registered with the Accounting and Corporate Regulatory Authority (ACRA). Foreign founders can own 100% of a Pte Ltd, but the company still needs a director ordinarily resident in Singapore, a company secretary based locally, and a registered Singapore office address. InvestinAsia’s Singapore market entry team handles the ACRA filing and the resident director gap that trips up most solo foreign founders.
Thai Limited Company and BOI Promotion
A Thai Limited Company is the default structure under Thailand’s Civil and Commercial Code, but the Foreign Business Act caps foreign ownership at 49% for most service and trading activities unless the company qualifies for an exemption. Board of Investment (BOI) promotion is the most common route to full foreign ownership: it exempts a company from the 49% cap for approved sectors like manufacturing, digital services, and R&D, and adds corporate tax breaks on top. Without BOI promotion or another route such as a Foreign Business License, the 49% ceiling applies by default. InvestinAsia’s Thailand team assesses which route fits a given business activity before registration begins.
WFOE (China)
A WFOE, or Wholly Foreign-Owned Enterprise, is a limited liability company in mainland China owned entirely by foreign investors, registered with the local Administration for Market Regulation (AMR, formerly SAMR) after approval through China’s foreign investment filing system. It is the structure most foreign companies use to operate directly in China rather than through a joint venture or representative office. InvestinAsia’s China setup team supports WFOE registration alongside the accounting and tax filing obligations that follow.
The remaining five markets use their own entity names, summarized below for quick comparison.
| Country | Common Entity Term | Registering Body |
|---|---|---|
| Vietnam | LLC (limited liability company) or JSC (joint-stock company) | Department of Planning and Investment (DPI) |
| Philippines | Domestic Corporation (with foreign equity) | Securities and Exchange Commission (SEC) |
| Cambodia | Private Limited Company, often filed as a Qualified Investment Project (QIP) | Council for the Development of Cambodia (CDC) |
| Hong Kong | Private Limited Company | Companies Registry (CR) |
| Dubai/UAE | Mainland LLC or Free Zone Company (FZE/FZC) | Department of Economic Development (DED) or the relevant free zone authority |
Comparing Indonesia against another market for a PT PMA?
InvestinAsia has run PT PMA setups for foreign founders since before Indonesia’s Positive Investment List existed. See what actually applies to your KBLI code.
Visa and Work Permit Terms
A visa or work permit term describes the legal status a foreign national needs to actually work inside the company they registered. This is the part investors miss most often. Owning shares in a company does not automatically give you the right to work in it. Every market on this list treats company registration and work authorization as two separate approvals.
In Indonesia, the relevant term is KITAS, a limited stay permit. An Investor KITAS is tied to a minimum shareholding in a PT PMA, while a Work KITAS is tied to a specific job role and sponsoring employer. Neither is optional for a foreign director who wants to sign documents, act as a bank signatory, or draw a salary. InvestinAsia’s Indonesia visa and KITAS service covers both categories alongside the underlying PT PMA.
Singapore and Malaysia both use the term Employment Pass, but the qualifying criteria differ. Singapore’s Employment Pass requires a minimum qualifying salary set by the Ministry of Manpower, reviewed periodically. Malaysia’s Employment Pass is tied to the company’s paid-up capital and the specific role being filled, and it is also how many foreign shareholders satisfy the resident director requirement described earlier. InvestinAsia’s Malaysia team often handles the Employment Pass and the Sdn Bhd registration as one coordinated process, since the two are rarely useful in isolation.
Thailand issues a Work Permit separately from the visa that allows entry, and both are required before a foreigner can legally work, even inside a company they own. Vietnam’s equivalent process runs through the Department of Planning and Investment and typically requires a labor demand approval before the work permit itself is issued. InvestinAsia’s Vietnam team handles that sequencing directly, since missing the labor demand step is a common cause of delay. The Philippines uses a 9(g) Pre-arranged Employment Visa paired with an Alien Employment Permit (AEP), issued by the Department of Labor and Employment before the visa itself can proceed. InvestinAsia’s Philippines team coordinates the AEP and visa application together to avoid the sequencing gap.
Notes from InvestinAsia Consultants
The mistake we see most often is a founder budgeting for company registration and stopping there, assuming the visa will “sort itself out” once the entity exists. In practice, banks routinely refuse to open a corporate account for a company whose director doesn’t yet hold the right visa, which stalls everything else. Sequencing entity setup and visa applications together, rather than one after the other, saves weeks in almost every market we work in.
Tax and Compliance Terms Come Up After Registration
Tax and compliance terms cover the ongoing filings a company owes after incorporation, separate from the one-time registration paperwork. This is where foreign investors most often assume “registered” means “done,” when it actually means the recurring obligations are just starting.
Indonesia’s NPWP (Nomor Pokok Wajib Pajak) is the company’s tax identification number, required under Income Tax Law No. 36 of 2008 before a PT PMA can open a bank account or complete its NIB business licensing. Separately, LKPM is a quarterly investment activity report filed with BKPM. It’s easy to treat as a formality, but missed LKPM filings are one of the more common triggers for compliance scrutiny on Indonesian PT PMA companies. InvestinAsia’s Indonesia tax compliance service handles NPWP registration and the recurring LKPM cycle together.
Singapore runs on a flat corporate tax rate with a Goods and Services Tax (GST) that becomes mandatory once taxable turnover crosses a set threshold in a 12-month period. Companies file an Estimated Chargeable Income return and an annual return with ACRA, both on fixed deadlines tied to the financial year end. Cambodia’s approach centers on the QIP designation from the CDC, which grants tax holidays and duty exemptions to qualifying investment projects, a route worth checking before assuming standard tax rates apply. InvestinAsia’s Cambodia team assesses QIP eligibility as part of initial market entry planning.
Hong Kong’s Business Registration Certificate (BR), issued by the Inland Revenue Department, is separate from the company’s Certificate of Incorporation from the Companies Registry, and both need annual renewal. The UAE splits its tax and licensing landscape between the mainland, regulated by each emirate’s Department of Economic Development, and dozens of free zones, each with its own registration authority and, in most cases, 100% foreign ownership without a local sponsor requirement. InvestinAsia’s Hong Kong team and Dubai team both handle the registration-plus-compliance combination that catches new entrants off guard.
What Regulatory Bodies and Acronyms Should You Recognize?
Regulatory body acronyms identify which government agency actually issues a given license, and mixing them up is a fast way to submit paperwork to the wrong office. The table below maps the primary agency behind company registration in each market.
| Country | Acronym | Full Name |
|---|---|---|
| Indonesia | BKPM / OSS | Ministry of Investment/Investment Coordinating Board; Online Single Submission system |
| Malaysia | SSM | Suruhanjaya Syarikat Malaysia (Companies Commission of Malaysia) |
| Singapore | ACRA | Accounting and Corporate Regulatory Authority |
| Thailand | DBD / BOI | Department of Business Development; Board of Investment |
| Vietnam | DPI | Department of Planning and Investment |
| Philippines | SEC | Securities and Exchange Commission |
| Cambodia | CDC | Council for the Development of Cambodia |
| Hong Kong | CR | Companies Registry |
| UAE | DED | Department of Economic Development (mainland); varies by free zone |
| China | AMR | Administration for Market Regulation (formerly SAMR) |
Notes from InvestinAsia Consultants
Clients occasionally confuse a country’s investment promotion agency, like Thailand’s BOI, with its general company registrar, like the DBD. They serve different purposes: one grants incentives and ownership exemptions, the other simply records that a company exists. You often need both, but they’re not interchangeable, and applying to the wrong one wastes a processing cycle you can’t easily get back.
Explore Market Entry Support Across Asia
If a term above matches the market you’re evaluating, InvestinAsia’s local teams handle registration, visas, and tax compliance in each of the following countries.
Talk to the Local Team for Your Market
Frequently Asked Questions
What’s the difference between a PT PMA and a Malaysian Sdn Bhd?
Both are foreign-owned limited liability company structures, but they sit under different laws and regulators. A PT PMA is registered through Indonesia’s OSS system under BKPM, while a Sdn Bhd is registered with Malaysia’s SSM. Capital requirements, ownership caps by sector, and director residency rules differ between the two, so the terms aren’t directly interchangeable in paperwork.
Do I need a local resident director in every Asian country?
No, but it’s common. Malaysia and Singapore both require at least one director ordinarily resident in the country, even for 100% foreign-owned companies. Indonesia does not impose the same resident director rule on a PT PMA, though director visa status still matters for banking and operational purposes.
What visa lets a foreign business owner actually work in the company they set up?
It depends on the country, and the terms are not interchangeable. Indonesia uses an Investor or Work KITAS, Singapore and Malaysia both use an Employment Pass, Thailand issues a separate Work Permit alongside the entry visa, and the Philippines pairs a 9(g) visa with an Alien Employment Permit. Company registration alone does not grant any of these.
Which Asian countries allow 100% foreign ownership?
Indonesia (in most Positive Investment List sectors), Singapore, Hong Kong, and most UAE free zones generally allow full foreign ownership. Thailand defaults to a 49% cap under the Foreign Business Act unless a company secures BOI promotion or another exemption route. Malaysia and Vietnam allow full ownership in many sectors but restrict others, so the answer depends on the specific business activity.
What happens if I miss a recurring compliance filing like LKPM or an annual return?
Consequences vary by country but rarely disappear on their own. In Indonesia, repeated missed LKPM filings can trigger compliance review from BKPM. In Singapore, late ACRA filings carry composition fines that apply to both the company and its officers. Treating registration as a one-time event rather than the start of a recurring obligation is one of the more expensive assumptions foreign investors make.
Is a representative office the same as a branch office?
No. A representative office generally cannot generate revenue and is limited to market research or liaison activity, which is common across Indonesia, Vietnam, and Singapore. A branch office, by contrast, can conduct commercial activity but remains legally part of the foreign parent company, meaning liabilities extend back to the parent rather than staying contained within a separate local entity.
Ready to move past the vocabulary and into the actual setup?
18+ years across 10 Asian markets means we’ve already mapped the terms above to real filings, real regulators, and real timelines.
References
1. Board of Investment of Thailand. (1999). Foreign Business Act, B.E. 2542 (official translation). Retrieved from
https://www.boi.go.th/upload/Foreign%20Business%20Act_5dd766122ff27.pdf
2. Government of Singapore, data.gov.sg. (2026). ACRA Information on Corporate Entities. Retrieved from
https://data.gov.sg/datasets/d_1cd970d8351b42be4a308d628a6dd9d3/view
3. UNCTAD Investment Policy Hub. Philippines Foreign Investment Act. Retrieved from
https://investmentpolicy.unctad.org/investment-laws/laws/95/philippines-foreign-investment-act
4. InvestinAsia. (2026). What Is a Sdn Bhd in Malaysia? Complete 2026 Guide. Retrieved from
What Is a Sdn Bhd in Malaysia? The Complete Guide to Registration, Costs, and Requirements
