News

In a press release issued on 15 September, Thailand's Revenue Department confirmed that Thailand has formally signed the Multilateral Competent Authority Agreement on the Exchange of GloBE Information (GloBE MCAA), and that the Organisation for Economic Co-operation and Development (OECD) added Thailand to the list of signatories on 8 September. Under the official timetable, Thailand will carry out its first exchange of GloBE Information Return data with the other parties to the agreement by December 2027. This means that global minimum tax information of large multinational groups with entities in Thailand will enter an automatic exchange channel.

Signing Process and Key Dates

On 16 June 2026, the Thai Cabinet resolved to approve Thailand's accession to the GloBE MCAA. The agreement was signed by Deputy Prime Minister and Minister of Finance Ekniti Nitithanprapas in his capacity as Thailand's competent authority, and the signing was announced publicly by Director-General of the Revenue Department Somsak Ananthawat. On 8 September 2026, the OECD formally added Thailand to the list of signatories, making Thailand an official member of this information exchange network.

In its press release, the Revenue Department set the first exchange for "within December B.E. 2570", which corresponds to by December 2027. There is a preparation period of roughly 15 months between signing and the first exchange, and this is the practical window for multinational groups in Thailand to consolidate their internal data and align their reporting bases.

What Is Exchanged and Who Is Covered

According to the official wording, the document exchanged under this agreement is the GloBE Information Return (GIR). It applies to "large multinational enterprise groups" and falls under Thailand's top-up tax measures.

It should be stressed that the Revenue Department's press release does not state a specific revenue threshold, does not cite a specific global minimum tax rate, and does not point to specific provisions of Thailand's domestic top-up tax law. Figures commonly quoted in the market, such as "EUR 750 million" and "15%", do not come from this official release. When assessing whether they are covered, companies must go back to the text of Thailand's top-up tax law and the rules of the jurisdiction where the group is headquartered and compare them item by item, rather than simply applying generic benchmarks.

Stated Policy Objectives and Enquiry Channels

The Revenue Department described two objectives for the signing: first, to make compliance easier and reduce the burden on large multinational groups of submitting the same set of data repeatedly in several countries; and second, to enhance the credibility and transparency of Thailand's tax system.

The Revenue Department has also announced dedicated enquiry channels: the RD Intelligence Center hotline 1161 and the dedicated email address topuptax@rd.go.th.

Key Takeaways

• The OECD formally added Thailand to the list of GloBE MCAA signatories on 8 September 2026; the Thai Cabinet approved accession on 16 June 2026.

• The first exchange of the GloBE Information Return (GIR) will take place by December 2027, leaving a preparation period of about 15 months.

• The agreement applies to "large multinational enterprise groups" and falls under Thailand's top-up tax measures.

• The official press release does not state a revenue threshold or a minimum tax rate. To determine whether you are in scope, go back to the text of the top-up tax law rather than applying generic benchmarks.

• The Revenue Department's hotline 1161 and dedicated email address topuptax@rd.go.th are now available.

Z&X Tip

At its core, GloBE information reporting depends on whether group-level financial and tax data can be extracted on a consistent basis across multiple jurisdictions. If a Thai entity's accounting basis differs from that of headquarters, and the conversion between Chinese and Thai financial statements relies on manual adjustments, this will surface directly as figures that do not reconcile when the filing date arrives. We recommend that Chinese-invested groups in Thailand do two things within this 15-month window: first, map the differences between the Thai entity's accounts and the group's consolidated financial statements and lock in the adjustment logic; second, confirm whether they fall within the scope of the top-up tax, with the conclusion subject to the determination of the competent authorities. The cross-border coordination and transfer pricing service modules (preparing contemporaneous documentation, designing compliant transfer pricing policies and responding to tax audits) within Z&X's "Tax Planning and Risk Control" service line are directly relevant to preparing for this agreement and can serve as a starting point.

Sources

• ประเทศไทยลงนาม GloBE MCAA พร้อมเดินหน้าแลกเปลี่ยนข้อมูลภาษีกลุ่มบริษัทข้ามชาติ (Press Release No. 22/2569) | The Revenue Department, Ministry of Finance, Thailand | 2026-09-15 | https://www.rd.go.th/fileadmin/user_upload/news/2569thai/news22_2569.pdf

• Revenue Department press release list | https://www.rd.go.th/59.html