Global Minimum Tax (Pillar Two)

The Pillar Two global minimum tax (15%) developed by the Organisation for Economic Co-operation and Development (OECD) has been enacted in Thailand and applies to fiscal years beginning on or after 1 January 2025. Large multinational groups with consolidated revenue of EUR 750 million or more must calculate their effective tax rate (ETR) and top-up tax, including the Qualified Domestic Minimum Top-up Tax (QDMTT), and file accordingly.

Pillar Two rules and Thailand's implementing regulations continue to evolve. Z&X closely tracks OECD and Thai legislative developments; final treatment follows the regulations and positions of the competent authorities in effect during the service period.

· Scoping: Determination of constituent entities and scope, and application of exclusions and safe harbors.

· Thai calculation and filing (core module): Global Anti-Base Erosion (GloBE) income adjustments, ETR calculation, top-up tax calculation (including QDMTT) and preparation of Thai returns.

· Group top-up tax modeling (optional module): Group-wide top-up tax modeling and scenario analysis, coordinated with head office.

· Local submission (optional module): Electronic submission and information reporting once the Thai returns have been completed.

Where first-year modeling and data set-up are needed, these can be agreed separately based on the project.

· Multinational groups meeting the consolidated revenue threshold: With constituent entities in Thailand subject to Pillar Two calculation and filing obligations.

· Thai subsidiaries of Chinese groups: Constituent entities that need to align data and calculation methodology with group headquarters.

· Very large or multi-jurisdiction groups: Scope tailored to complexity.

· Kick-off and scoping (within 1 week of engagement): Confirm scope, complete the scoping assessment and assemble the project team.

· Data alignment (1–3 weeks after documents are complete): Coordinate with head office to gather the information required for GloBE calculations.

· Calculation and modeling: GloBE adjustments, ETR and top-up tax calculations, and scenario modeling.

· Return preparation: Preparation of Thai returns and information returns.

· Review, finalization and submission: Review and sign-off, finalization and timely local submission.

The core calculation and filing work takes around 6–10 weeks, depending on the readiness of group data. We recommend engaging with head office on data early.

· Pillar Two calculation working papers and notes: A complete record of the calculation process and methodology.

· ETR and top-up tax schedules: ETR and top-up tax results for Thai entities.

· Thai returns: Preparation of the main returns is included in the core module.

· Group top-up tax modeling report (optional): Group-wide modeling and scenario analysis.

· Local submission confirmation (optional): Confirmation that electronic submission and information reporting are complete.

The Compliance Self-Check for Chinese-Invested Companies in Thailand covers 13 checks across six areas: shareholding structure, registered address and property, staff and employment, accounts and documents, BOI compliance, and tax filing. Each check comes with clear criteria, so you can see whether you are in the green, yellow or red zone and what to fix first.

Free download: Compliance Self-Check for Chinese-Invested Companies in Thailand (PDF, 3 pages)

Unsure about any item after the self-check? Book a pillar two impact assessment →

· How does the global minimum tax (Pillar Two) affect Chinese-invested companies in Thailand and BOI incentives?

· What tax and operational benefits can BOI provide?

· Are there significant differences in tax burden for a Chinese-invested company in Thailand when repatriating funds in the form of dividends, service fees and technology royalties?

· Under what circumstances is a transfer pricing document required for a Chinese-invested company in Thailand?

Want advice tailored to your company? Book a Pillar Two (global minimum tax) impact review consultation →

Z&X follows Thailand's global minimum tax legislation and the GloBE information exchange. Some of our published content:

· Is Applying for BOI Worth It? One Table to Work It Out

· Are there significant differences in tax burden for a Chinese-invested company in Thailand when repatriating funds in the form of dividends, service fees and technology royalties?

· Under what circumstances is a transfer pricing document required for a Chinese-invested company in Thailand?

· Our licenses and certificates: three licensed firms in China and Thailand

Want to assess the impact on your group's Thai entity? Book a Pillar Two impact review →

Articles from our Thailand Investment Guide related to this service:

· Thailand Signs the GloBE MCAA: Tax Information of Multinational Groups Will Be Exchanged

· Tax Information Exchange Violations: Fines of Up to THB 500,000 per Count

View all guide articles →