Thailand consults on a Revenue Department framework for qualified refundable tax credits

Thailand’s Revenue Department has opened a consultation on the principles of a Draft Act on Qualified Refundable Tax Credits (QRTCs). The official notice invites comments from 6 October to 5 November 2026. The accompanying bilingual consultation paper sets out thirteen principles for a new incentive framework, including electronic certificates, tax settlement, cash refunds and transfers.

This is a consultation on legislative principles. It does not enact a credit, open applications or establish a commencement date. The paper identifies matters for future Royal Decrees and Revenue Department rules, so it cannot yet establish that any particular investment will qualify or that a credit will satisfy the GloBE definition of a QRTC.

What changes from the earlier policy announcement?

The QRTC policy itself is not new. In its 4 August 2025 announcement, the Board of Investment described proposed amendments to the National Competitiveness Enhancement for Targeted Industries Act, together with parallel Revenue Department changes. It identified R&D, skills, productivity and sustainable investment as intended areas of support.

The October 2026 paper provides a more specific proposed administrative and funding architecture. The Revenue Department would administer the incentive; a committee chaired by its Director-General would decide annual policies and allocations and approve individual applications. Eligibility, qualifying expenditure or activities, and credit rates or amounts would be prescribed by Royal Decree. The earlier policy examples therefore should not be treated as the final statutory eligibility list. (Principles 2, 4–7.)

Certificates, tax settlement and refunds

Following approval, the Director-General would issue an electronic certificate for the approved amount. The recipient could use it to settle income tax and other taxes or duties specified by Royal Decree. This is a proposed mechanism for paying liabilities with an incentive entitlement; the paper does not identify every tax against which it could be used. (Principles 8–9.)

The refund timetable contains distinct dates. Principle 1 envisages a cash refund of the unused balance within four years from a prescribed date. Principle 10 gives the certificate four years’ validity from committee approval, but allows an application for the remaining cash amount after three years from the incentive’s commencement date. Principle 7 separately allows the committee to determine the incentive’s start and expiry dates. These clocks require coordination in the eventual legislation and implementing rules.

Principle 11 would permit transfers under Director-General rules. A transferee would receive the remaining credit amount and remaining incentive period: the principles do not provide a fresh four-year period on transfer. (Principles 10–11.) The proposals accordingly concern both the recipient’s ability to monetise the incentive and the legal conditions governing that entitlement.