On 15 September 2026, the Thai Revenue Department (TRD) issued Notification Por. Chor. Sor. 22/2569 announcing that Thailand has formally signed the Global Anti-Base Erosion (GloBE) Multilateral Competent Authority Agreement (MCAA). This agreement, developed under the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS) Pillar Two, establishes a standardized legal mechanism for the automatic exchange of Country-by-Country (CbC) reports and GloBE-specific information between competent authorities of participating jurisdictions. The signing marks a critical step in Thailand’s implementation of the global minimum tax regime, which applies to multinational enterprise (MNE) groups with consolidated annual revenues of EUR 750 million or more. The regime includes the Qualified Domestic Minimum Top-Up Tax (QDMTT), the Income Inclusion Rule (IIR), and the Undertaxed Profits Rule (UTPR), effective for fiscal years commencing on or after 1 January 2025. Thailand’s domestic legislation, enacted via Royal Decree No. 738 B.E. 2567 (2024) under the Revenue Code Amendment Act (No. 28) B.E. 2567, transposes these rules into Thai law. The GloBE MCAA eliminates the need for bilateral competent authority arrangements, streamlining the exchange process and ensuring that Thai tax authorities receive timely, standardized data on the global tax positions of MNEs operating in Thailand. The first exchanges are expected to occur by June 2027 for the 2025 fiscal year data. The TRD emphasized that the agreement enhances tax transparency, reduces compliance burdens through standardized reporting, and strengthens Thailand’s ability to protect its tax base against profit shifting. Taxpayers should note that the exchanged information will be used for risk assessment, audit selection, and the calculation of top-up taxes under the QDMTT and IIR mechanisms.
Key Takeaways
- Automatic Exchange of GloBE Information Operational: The MCAA enables the automatic, annual exchange of CbC reports and GloBE computation data (including effective tax rates, top-up tax amounts, and constituent entity details) among over 140 Inclusive Framework members. For Thai tax authorities, this means immediate access to granular data on MNE groups’ global allocation of income, taxes paid, and economic activity, facilitating targeted audits and reducing information asymmetry.
- Direct Impact on Thai and Foreign MNE Groups: Thai-headquartered MNE groups (Ultimate Parent Entities) must file GloBE Information Returns with the TRD within 15 months after the fiscal year-end (or 18 months for the first year). Foreign MNE groups with Thai constituent entities are subject to the QDMTT if Thailand enacts a qualifying domestic top-up tax, and their data will be shared with the UPE’s jurisdiction for IIR purposes. The TRD has issued detailed guidance on registration, filing procedures, and transitional safe harbors (e.g., the Transitional CbC Reporting Safe Harbor and the Transitional UTPR Safe Harbor) via Notifications Por. Chor. Sor. 5/2569 and 6/2569.
- Strengthened Dispute Resolution and Tax Certainty: The MCAA incorporates the Mutual Agreement Procedure (MAP) under existing bilateral tax treaties, allowing MNEs to resolve disputes arising from GloBE top-up tax assessments. This provides a binding mechanism to eliminate double taxation and ensures consistent application of the GloBE rules across jurisdictions. The TRD has committed to publishing annual statistics on exchange volumes and MAP cases to promote transparency.
Disclaimer: This article is compiled and summarized by the AI based on publicly available information and is for general information purposes only. It does not constitute any form of formal tax advice, legal opinion, or basis for performance. Please consult a qualified professional tax advisor or legal counsel for tax advice.
Source: Read Official Announcement