New tax law implemented to collect global minimum tax of 15% effective from 1 January 2025

New tax law implemented to collect global minimum tax of 15% effective from 1 January 2025.

On 26 December 2024, the Emergency Decree on Top-up Tax was published in the Royal Gazette to support the collection of a global minimum tax of 15% from large multinational enterprises. The new law is based on the Pillar Two Global Anti-Base Erosion (GloBE) Model Rules.

The Emergency Decree is effective from 1 January 2025 and applies to large multinational enterprises (MNEs) operating in Thailand, whether they are Thai MNEs investing abroad or foreign MNEs investing in Thailand. These MNEs must have annual revenues of at least EUR 750 million in the consolidated financial statements of their Ultimate Parent Entity (UPE) for at least two of the four accounting periods immediately preceding the accounting period under consideration.

The Revenue Department will be responsible for proposing additional laws and setting operational guidelines as appropriate to collect the top-up tax, in accordance with standards established by the OECD.

The Revenue Department newsletter in English about the new law is here