On 22 October, Thailand's Revenue Department issued a Country-by-Country Report (CbCR) reminder: multinational groups with consolidated revenue of at least THB 28 billion in the preceding fiscal year must file within 12 months after the end of the fiscal year; for fiscal years ending 31 December 2025, the report is due by 31 December 2026.
What Is a Country-by-Country Report
The Revenue Department's infographic states that a Country-by-Country Report is filed by large multinational groups under Organisation for Economic Co-operation and Development (OECD) standards, reporting their operations in each jurisdiction, including revenue, profit, tax paid and number of employees, and is used to assess the risk of tax avoidance and cross-border profit shifting.
Who Must File
The threshold: total consolidated revenue in the group's consolidated financial statements of at least THB 28 billion (about RMB 6.16 billion) in the fiscal year preceding the reporting fiscal year.
Two types of entities have a filing obligation in Thailand:
An ultimate parent company or parent partnership established under Thai law (Ultimate Parent Entity, UPE);
A surrogate filing entity established under Thai law that has been designated in writing to file on the group's behalf and meets the statutory conditions (Surrogate Parent Entity, SPE).
When to File
Within 12 months from the end of the fiscal year. The Revenue Department's example: for a fiscal year ending 31 December 2025, the report must be submitted by 31 December 2026. Groups that use the calendar year as their fiscal year are therefore due at the end of this year.
How to File
Filing is done through the Revenue Department's CbCR system (https://cbcr.rd.go.th/aeoi/ ) in four steps:
Register and wait for approval;
Submit a Notification, filling in CbCR-related information as required by the system;
Prepare an XML file in English in accordance with OECD standards and Revenue Department requirements, and upload it;
Check the filing result; a confirmation of receipt must be received from the system.
Three Common Pitfalls
The infographic specifically notes:
Submitting a Notification is not the same as submitting the CbCR; submitting only the Notification does not count as filing;
Check the Notification every time, especially the details of the reporting entity and the fiscal year;
File completely within the deadline, ensure the XML file is correct, and check the filing result.
Help is available through the regulations, preparation guidelines, user manual and FAQs on the CbCR system website, the Revenue Department hotline 1161, and the email address CbCR@rd.go.th.
Relevance for Chinese-Invested Companies in Thailand
The CbCR obligation rests with the ultimate parent entity or the designated surrogate filing entity. For groups whose parent company is in China, the Thai subsidiary is generally not the ultimate parent entity; whether it needs to file or notify in Thailand depends on the group's filing arrangements and the specific conditions under Thai rules, and must be assessed case by case.
Key Points
Threshold: group consolidated revenue of at least THB 28 billion in the preceding fiscal year.
Deadline: within 12 months after the end of the fiscal year; 31 December 2026 for calendar-year groups.
Channel: cbcr.rd.go.th/aeoi/, in four steps: registration, Notification, XML upload and checking the result.
Submitting a Notification does not complete the filing; a system confirmation must be received.
Z&X Insight
The CbCR, related party transaction disclosure and the Local File form one set of documents: the revenue, profit and employee data a group reports in each jurisdiction should reconcile with the related party transfer pricing of its Thai company. Z&X Transfer Pricing Services help Chinese-invested companies in Thailand review related party transactions and cross-border payment arrangements, and can help groups confirm the filing role of their Thai entity and check that the relevant data are prepared on a consistent basis.
Sources
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