Thailand’s BOI will allow promoted companies to claim cash refunds for unused tax credits under new global minimum tax rules.

Thailand’s Board of Investment (BOI) plans to introduce Qualified Refundable Tax Credits (QRTCs) under the Pillar Two Global Minimum Tax (GMT) framework. This allows eligible promoted companies to receive cash refunds for unused tax credits, which are classified as income rather than reducing covered taxes, thus preserving the Pillar Two effective tax rate.

The Commission on the National Competitiveness Enhancement for Targeted Industries Policies, with the BOI acting as secretariat, has approved amendments to the National Competitiveness Enhancement for Targeted Industries Act of B.E. 2560 (2017). These amendments include new rights and investment incentives such as tax credit refunds aligned with the OECD’s GMT (Pillar Two) standards.

The proposed changes will be submitted to the Cabinet for final approval before entering the legislative process. Simultaneously, the Revenue Department will update tax regulations to enable implementation in accordance with OECD’s QRTC guidelines, where such credits are treated as income for Pillar Two purposes.

With the GMT’s enforcement from 1 January 2025, applying a 15% minimum tax rate on multinational groups with consolidated revenue exceeding 750 million EUR, the BOI is adjusting its policies to lessen its impact on investment. Approximately 1,500 companies in Thailand, mostly foreign-owned, and about 100 Thai firms are expected to be affected.

Narit Therdsteerasukdi, BOI Secretary General, emphasised after the Commission meeting—chaired by Deputy Prime Minister and Finance Minister Pichai Chunhavajira—that these legislative updates are crucial to boosting global investor confidence. The new tax rules create an opportunity to attract high-quality investments, enhance R&D, develop skilled talent, and foster a tech-friendly ecosystem.

QRTCs will support promoted companies investing in research and development, advanced skills, production efficiency and sustainable projects to improve competitiveness. Companies can apply these credits to reduce tax liabilities or claim cash refunds for unused amounts, thereby enhancing liquidity for growth.