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Thailand Emergency Decree on Top-up Tax B.E. 2567 Takes Effect January 2025

Thailand's Emergency Decree on Top-up Tax, B.E. 2567 (2024), was promulgated in the Royal Gazette on 26 December 2024 and takes effect for accounting periods commencing on or after 1 January 2025. The decree applies to large MNEs with consolidated financial statement revenues of at least €750 million and establishes a globally-aligned minimum tax floor in line with the OECD Pillar Two framework. The Revenue Department will propose secondary legislation and implement electronic systems for GloBE Information Return submissions. By 2024, 28 countries including Vietnam, Germany, France, and the UK have enacted similar laws, with Malaysia, Singapore, Indonesia, and Hong Kong expected to follow in 2025.