GloBE Country Guide: Thailand

Summary

Status	Enacted Law
Law	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

Legislation
General
Differences to Model Rules
Qualifying Domestic Minimum Top-Up Tax
Administration and Filing
Penalties

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Lee Hadnum

Lee is a qualified Chartered Accountant and a former Senior Tax Analyst at Bloomberg Tax. Lee began his career in Ernst & Young's Entrepreneurial Services department and has 20 years of international tax planning experience.

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