🇹🇠Tax26 Dec 2024
Thailand brings in the 15% global minimum tax from 2025
Thailand's Emergency Decree on Top-Up Tax B.E. 2567 (2024), published in the Government Gazette on 26 December 2024, applies the OECD's 15% global minimum tax to large multinational groups from 1 January 2025. It was made by emergency decree to meet the start date. Groups with Board of Investment tax privileges are particularly affected, as their incentives may now be topped up.
The decree implements the OECD's Pillar Two global anti-base erosion (GloBE) rules through an expedited procedure.
What changed
- A 15% minimum effective tax rate for multinational groups with revenue of at least EUR 750 million, from 1 January 2025.
- Thai entities taxed below 15%, for example under Board of Investment incentives, may pay top-up tax.
- Further rules and filing guidance come from the Revenue Department.
Who is affected
Thai entities of large groups, especially those with BOI privileges, and their tax teams.