Revenue Department deputy director-general Panuwat Luengwilai said on Friday that the top-up tax came into effect on January 1 this year.
The royal decree stipulates that multinational enterprises which pay corporate income tax at a rate below 15% will need to pay the difference (to reach 15%) in the country where its parent company is headquartered.
The top-up tax would affect 100 Thai multinational companies headquartered overseas, and 1,100 foreign multinational corporations in Thailand which have received tax benefits from the Board of Investment (BOI).
These companies generate revenue of at least 750 million euros or 26 billion baht based on their consolidated financial statements, he said.
Panuwat noted that the top-up tax aligns with the global minimum tax (GMT) initiative led by the Organisation for Economic Co-operation and Development (OECD), aiming to ensure fairness in global tax competition.
He confirmed that the department and the BOI were currently holding discussions on offering financial benefits instead of tax benefits, such as qualified refundable tax credit and cost reduction for setting up research facilities or developing human resources.
Panuwat also asked multinational corporations subject to the royal decree to pay this year’s tax within 18 months. He expects to recognise revenue of 12 billion baht in June 2027.
He emphasised that the top-up tax had nothing to do with corporate income tax, confirming that it aims to protect the national interest.
“If Thailand doesn’t have a top-up tax law, the country will lose additional tax revenue that should be collected compared to other countries that have the top-up tax law,” he said.