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GloBE Country Guide: Thailand

Summary

Status Enacted Law
LawOn October 21, 2025, the Thai Revenue Department issued three Notifications that address (1) the definition of Acceptable Accounting Standards, (2) the definition of refundable dividend taxes not within the scope of covered taxes, and (3) the definition of flow-through entities and the location rules.

On December 26, 2024, Thailand published the Emergency Decree on Top-up Tax, B.E. 2567 (2024) in its Official Gazette to implement the GloBE provisions from January 1, 2025.

On March 1, 2024, the Thai Revenue Department published a draft law on the implementation of Pillar Two.
Effective DateAccounting periods beginning on or after January 1, 2025
IIRYes (2025)
UTPRYes (2025)
QDMTTYes (2025)
Filing DeadlinesStandard
Safe HarboursNone

Contents
  1. Legislation
  2. General
  3. Differences to Model Rules
  4. Qualifying Domestic Minimum Top-Up Tax
  5. Administration and Filing
  6. Penalties

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