Thailand Emergency Decree on Top-up Tax B.E. 2567 Takes Effect January 2025
Summary
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.
“These MNEs must have annual revenues of at least €750 million in the consolidated financial statements of their Ultimate Parent Entity (UPE) for at least two of the four accounting periods immediately preceding the accounting period under consideration.”
MNEs subject to this decree should initiate a gap analysis against OECD Pillar Two rules now, as the January 1, 2025 effective date leaves limited preparation time. Groups with Thai subsidiaries or Thai ultimate parent entities should confirm whether the €750M threshold is met on a group-wide basis and assess which jurisdictions will trigger top-up tax liability. The Revenue Department's emphasis on electronic filing suggests GloBE Information Returns will be required in a structured digital format—groups without existing Pillar Two reporting infrastructure should prioritize building or acquiring that capability. Contact: topuptax@rd.go.th for official guidance.
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What changed
The Emergency Decree on Top-up Tax, B.E. 2567 (2024), introduces a qualified domestic minimum top-up tax in Thailand for large multinational enterprises meeting the €750 million consolidated revenue threshold in at least two of the four preceding accounting periods. The top-up tax is set at the globally agreed minimum rate under the OECD Global Minimum Tax framework, creating a 15% effective floor for corporate taxation. Affected MNEs—whether Thai enterprises investing abroad or foreign enterprises investing in Thailand—must calculate and remit top-up tax in alignment with OECD Pillar Two rules.
Large MNEs subject to the decree should monitor for forthcoming secondary legislation from the Revenue Department and prepare for GloBE Information Return submissions through the electronic filing system. Multinational groups with Thai operations should assess their top-up tax exposure across all jurisdictions where comparable laws have been enacted. The Revenue Department notes that additional countries including Malaysia, Singapore, Indonesia, and Hong Kong are expected to implement similar legislation in 2025, increasing the global compliance footprint for affected groups.
Archived snapshot
Apr 23, 2026GovPing captured this document from the original source. If the source has since changed or been removed, this is the text as it existed at that time.
News No. : 6/2025 Date : 27 December 2024 thSubject : Emergency Decree on Top-up Tax, B.E. 2567 (2024) Officially Promulgated
in the Royal Gazette
..............................................................................................................................................................................
The Revenue Department, through the Ministry of Finance, proposed the draft
Emergency Decree on Top-up Tax to the Cabinet, which approved it on 11 December 2024. thOn 26 December 2024, the Emergency Decree on Top-up Tax, B.E. 2567 (2024), was officially thpromulgated in the Royal Gazette. The Emergency Decree will apply to large multinational enterprises (MNEs) with consolidated financial statement revenues of at least €750 million and will take effect for accounting periods commencing on or after 1 January 2025. st
The enactment of the Emergency Decree on Top-up Tax aims to enable
Thailand to retain its right to collect additional tax revenue, thereby safeguarding the nation's interests. Without such legislation, Thailand risks losing potential tax revenue to jurisdictions that have already implemented comparable Top-up Tax laws. By 2024, 28 countries have enacted such laws, including Greece, South Korea, Canada, Japan, Denmark, Turkey, the Netherlands, New Zealand, France, Finland, Germany, Spain, Sweden, the United Kingdom, Australia, Italy, Ireland, and Vietnam. For 2025, countries such as Malaysia, Singapore, Indonesia, and Hong Kong are expected to follow suit. The Emergency Decree on Top-up Tax applies to large MNEs operating in Thailand, whether they are Thai MNEs investing abroad or foreign MNEs investing in Thailand. These MNEs must have annual revenues of at least €750 million in the consolidated financial statements of their Ultimate Parent Entity (UPE) for at least two of the four accounting periods immediately preceding the accounting period under consideration. The Top-up Tax will be levied at the globally agreed minimum tax rate, in alignment with the Global Minimum Tax framework, thereby establishing a floor on tax competition. The Revenue Department drafted the Emergency Decree in accordance with the standards established by the OECD, ensuring consistency with similar laws in other jurisdictions, thereby reducing the compliance burden for MNEs investing in Thailand.
Pinsai Suraswadi, Director-General of the Revenue Department, states that
the enactment of the Emergency Decree represents a significant milestone in promoting
investment while simultaneously ensuring Thailand's fiscal sustainability. Following
the Emergency Decree's enactment, the Revenue Department will propose secondary legislation to provide additional details in accordance with the standards established by the OECD. In respect of tax filings, tax payments, the submission of GloBE Information Returns, and notifications, the Revenue Department will ensure these processes are seamlessly facilitated
through a fully electronic system. To support compliance with the law, the Revenue Department will host seminars and develop e-learning platforms to enhance awareness and understanding among taxpayers and key stakeholders, including tax advisors and auditors. Taxpayers and stakeholders are encouraged to stay updated through the Revenue Department's official website and social media channels. For any further enquiries, kindly direct your correspondence to topuptax@rd.go.th
********************************************* The Revenue Department is here to serve people
Public Relations, Office of the Secretary 90 Soi Phaholyothin 7, Phaholyothin Road , Bangkok 10400 Tel. 0 2272 9529-30 Fax. 0 2617 3324 RD Intelligence Center Tel. 1161
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