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2025 Tax Updates 1#
The Revenue Department has officially published the Emergency Decree on Top-up Tax B.E. 2567 (2024), which was released on December 26, 2024. These provisions will take effect for accounting periods beginning on or after January 1, 2025. The Top-up Tax is linked to the global minimum tax rate established by the OECD, with the minimum rate set at 15%.
Any constituent entity (CE) located in Thailand that is a member of a multinational enterprise (MNE) group with consolidated revenues exceeding EUR 750 million in at least two of the four fiscal years immediately preceding the reporting fiscal year is required to comply with the Top-up Tax under this Emergency Decree.
In such cases, all CEs in Thailand will be required to submit the following documentation to the Thai Revenue Department (TRD) within 15 months after the end of the accounting period:
- 1. The Notification
- 2. The GloBE Information Return
- 3. The Top-up Tax Return and Top-up Tax payment (if applicable)
The format and submission method for these documents will be announced through subordinate laws at a later stage.
Surcharges and Penalties
- A penalty of 100% of the tax shortfall applies to taxpayers who file incorrect returns.
- A penalty of 200% of the tax shortfall applies to taxpayers who fail to file returns.
- An additional monthly surcharge of 1.5% on any top-up tax shortfalls is applicable, capped at 100% of the tax shortfall.
Key Considerations
The effective tax rate under this Emergency Decree is calculated by dividing the amount of adjusted covered taxes by the amount of net GloBE income. Both figures must comply with the criteria, methods, and conditions outlined in forthcoming Ministerial Regulations.