Thailand’s Ministry of Finance has introduced prescribed settlement fines for specified offences under the country’s tax information exchange framework, covering false statements and reporting non-compliance.
Thailand’s Revenue Department has published a notification from the Ministry of Finance (MoF) on 9 September 2026, establishing specific penalties for failing to comply with certain requirements of the Emergency Decree on Exchange of Information for Implementation of the International Agreements on Taxation, B.E. 2566 (2023).
The Decree provides for the exchange of information upon request and the automatic exchange of financial account information under frameworks such as CRS and FATCA.
Fixed settlement fines
A settlement fine of THB 500,000 per count applies to the Section 28 offence involving intentional false statements or concealment of factual truths when performing duties or submitting information under Section 12, Section 17 or Section 18.
For the Section 29 offence, a settlement fine of THB 300,000 per count applies to reporting entities or duty-bearers that fail to comply with the reporting requirements under Section 20.
The notification becomes enforceable from the date of its publication in the Royal Gazette. It was signed by Finance Minister Ekniti Nitithanprapas.
Tax information exchange framework
The Royal Decree on Information Exchange for Compliance with International Agreements Regarding Taxes B.E. 2566 (2023) was enacted on 29 March 2023 and published in the Royal Gazette on 30 March 2023, coming into force the following day.
The decree established the statutory framework for Thailand to meet international tax transparency obligations, including the exchange of information upon request and the automatic exchange of financial account information under frameworks such as CRS and FATCA.
Thailand’s competent authorities can exchange relevant tax information upon request from foreign partner jurisdictions under Double Taxation Agreements (DTAs) and multilateral agreements.
Automatic exchange requirements
Under the automatic exchange framework, Reporting Financial Entities must conduct due diligence to identify reportable accounts and obtain declarations of tax residency from customers opening new accounts.
The requirements apply to several categories of financial and other entities, including financial institutions, securities companies, Specialized Financial Institutions (SFIs), licensed life insurance companies, derivatives business operators, escrow agents and custodians, credit card operators, trustees under Capital Market Trust law and other entities specified by the Minister of Finance.
Reporting entities must submit reportable account information to the Revenue Department annually by June 30 of the following year.
The information includes the name, address, Tax Identification Number (TIN) and date and place of birth of account holders or controlling persons, together with account numbers, calendar year-end balances or cash surrender values, interest and other returns.
Reporting entities must retain due diligence records, evidence and customer tax declarations for at least six years from the end of the calendar year in which the due diligence was completed.
Other penalties
The broader penalty framework provides for administrative fines of up to 200,000 THB for failures to comply with certain Director-General orders concerning information requests, reporting corrections and anti-avoidance requirements.
Intentional submission of false statements or concealment of facts can result in criminal fines ranging from THB 50,000 to THB 500,000, while failure to retain records for the required six-year period can attract a fine of up to 300,000 THB.
Unlawful disclosure of information obtained through official duties under the decree can carry imprisonment of up to 1 year, a fine of up to THB 100,000 or both.
The Revenue Director-General is also empowered to compound or settle certain monetary criminal offences under Sections 28 and 29.
International tax commitments
The decree supports Thailand’s obligations as a member of the OECD’s Global Forum on Transparency and Exchange of Information for Tax Purposes and under DTAs, the Multilateral Convention on Mutual Administrative Assistance in Tax Matters and the Common Reporting Standard Multilateral Competent Authority Agreement (CRS MCAA).
It also provides rules for the exchange of information upon request, including requirements concerning the information sought, the taxpayer concerned and the grounds for the request.
The framework allows Thai authorities to reject requests in specified circumstances, including where obtaining or exchanging the information would breach Thai law, disclose protected commercial or professional secrets, conflict with public order or good morals, or where the requesting jurisdiction cannot ensure confidentiality or reciprocity.
