Thailand's Revenue Department has opened a public consultation on a draft act that would introduce Qualified Refundable Tax Credits (QRTCs), allowing promoted companies to claim cash refunds on unused credits under the Pillar Two Global Minimum Tax framework.
Thailand’s Revenue Department has launched a public consultation on the principles of the Draft Act on Qualified Refundable Tax Credits, which would give promoted companies a new form of investment incentive compatible with the Pillar Two Global Minimum Tax framework.
How the credits would work
A recipient could use an approved QRTC amount to pay tax liabilities and claim any remaining balance as a cash refund within four years from the prescribed date. As QRTCs are treated as income rather than as a reduction of covered taxes, they do not negatively affect the Pillar Two effective tax rate.
The Thai Board of Investment first announced the planned implementation of QRTCs in August 2025. They are intended for investments or expenditures in areas such as research and development, advanced skills development, production efficiency improvement and sustainable investment.
Administration and funding
The Revenue Department would administer the incentives, with powers to summon persons or documents and conduct searches, similar to those under the Revenue Code.
To fund the scheme, it could retain up to 1% of corporate income tax collected, after deducting withholding tax remitted under Form P.N.D. 53, instead of remitting it as government revenue.
Eligibility and approval
Eligibility requirements, eligible expenditures or activities, and applicable rates or amounts would be prescribed by Royal Decree. Companies and juristic partnerships would apply to the Revenue Department, which would review applications and submit them to a committee.
The committee would be chaired by the Director-General of the Revenue Department, with representatives of relevant agencies and qualified experts as members. It would set annual policies and incentive amounts, approve, modify or revoke incentives, and fix their commencement and expiry dates.
Certificates, refunds and transfers
Once an incentive is approved, the Director-General would issue an electronic QRTC incentive certificate, valid for four years from the date of approval. The certificate could be used to pay income tax or other taxes and duties prescribed by Royal Decree.
After three years from the commencement date, recipients could apply for a cash refund of any remaining amount. Incentives may also be transferred under rules set by the Director-General, with the transferee entitled to the remaining amount and the remaining period.
Safeguards and penalties
The committee could modify or revoke an incentive if a recipient ceases to meet the eligibility requirements, fails to comply with the prescribed rules or conditions, or does not cooperate with an inspection. Amounts already used or refunded in cash would be recovered with interest at the prescribed rate.
Penalties are also proposed for failing to provide statements, submit documents or evidence, or facilitate an inspection, as well as for false statements, false evidence and fraudulent conduct. The department says the committee system and criminal penalties are necessary because QRTCs result in a loss of government revenue.
Stakeholders and consultation
The consultation covers Thai and foreign companies and juristic partnerships, and government agencies including the Ministry of Finance, the Bureau of the Budget, the Board of Investment and the Eastern Economic Corridor Office. It also covers private-sector bodies such as the Thai Chamber of Commerce and the Board of Trade of Thailand and the Federation of Thai Industries.
The consultation information document and questionnaire are available in Thai and English. The department says the measure is intended to support targeted industries, high-value employment, technological innovation and long-term economic growth, while protecting the country’s fiscal position.
