On March 1, 2024, the Thai Revenue Department initiated a public consultation on draft legislation for enforcing the Pillar 2 global minimum tax rules in Thailand. The legislation includes the Pillar 2 income inclusion rule (IRR) and undertaxed payment rule to ensure a minimum tax rate of 15% for multinational enterprise (MNE) groups with annual consolidated revenue exceeding EUR 750 million in at least two of the preceding four accounting periods. The proposed legislation introduces a domestic minimum top-up tax for in-scope group members. The draft didn’t set any effective date.
On 7 March 2023, the Thai Cabinet approved measures to incorporate global minimum tax regulations as part of the base erosion and profit shifting (BEPS) 2.0 Pillar Two rules issued by the OECD with a planned implementation in 2025. The deadline for feedback on the draft legislation is 15 March 2024.
