| Status | Enacted Law |
| Law | On December 29, 2025, the Thai Cabinet approved 4 draft laws/regulations on the implementation of the Pillar 2 rules in Thailand. The laws need to be published in the Official Gazette. The laws are: Draft Royal Decree on the criteria for considering liability to additional tax for groups of multinational legal entities undergoing corporate restructuring, together with an explanatory note (principles and rationale) and a summary analytical note. Draft Royal Decree prescribing legal entities that are not related legal entities, together with an explanatory note (principles and rationale) and a summary analytical note. Draft Ministerial Regulation, issued under the Executive Decree on Top-Up Tax, B.E. 2567 (2024), on the allocation of residual additional tax received by Thailand to related legal entities established in Thailand, together with an explanatory note (principles and rationale) and a summary analytical note. Draft Ministerial Regulation, issued under the Executive Decree on Top-Up Tax, B.E. 2567 (2024), on adjustments to income, expenses and taxes within scope for the calculation of additional tax, together with an explanatory note (principles and rationale) and a summary analytical note. On December 4, 2025, the Thai Revenue Department issued Notification No 4 and 5 on the determination of employees and tangible assets for the purpose of the Substance-Based Income Exclusion. On November 18, 2025, Thailand’s Ministry of Finance issued notification no. 1 under the Minimum Tax Law to provide for the Transitional SBIE rates. On 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 Date | Accounting periods beginning on or after January 1, 2025 |
| IIR | Yes (2025) |
| UTPR | Yes (2025) |
| QDMTT | Yes (2025) |
| Filing Deadlines | Standard |
| Safe Harbours | None |
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