Thailand joins GloBE information exchange for multinational groups.
Thailand has taken another step towards integrating its tax system with the global financial reporting network. The agreement supports the international exchange of tax information relating to the global minimum tax rules, which primarily apply to some of the world’s largest multinational corporations. Its significance, however, extends beyond the companies directly affected.
Deputy Prime Minister and Finance Minister Ekniti Nitithanprapas announced on 15 September that Thailand had signed the Multilateral Competent Authority Agreement on the Exchange of GloBE Information (the GloBE MCAA). The OECD formally listed Thailand as a signatory on 8 September. As a result, another section of Thailand’s tax system is joining an international information exchange network.
The Global Minimum Tax and information exchange
GloBE stands for Global Anti-Base Erosion and forms the core of Pillar Two of the OECD and G20 international corporate tax reforms. The framework sets a 15% minimum effective tax rate for extremely large multinational groups. Where effective taxation falls below that rate, a top-up tax can become payable.
Thailand introduced the Global Minimum Tax itself in December 2024, under the Emergency Decree on Top-up Tax B.E. 2567. The regime applies to accounting periods beginning on or after 1 January 2025 to groups with consolidated annual revenues of at least EUR 750 million. The GloBE MCAA provides the mechanism for participating tax administrations to exchange GloBE Information Returns (GIRs). This means covered groups do not need to file substantially similar disclosures separately in each jurisdiction. Thailand expects its first GIR exchanges by December 2027.
The domestic rationale is straightforward: Thailand has long used Board of Investment incentives to attract large investors, and under Pillar Two, incentives that push a covered group’s effective rate below 15% risk having the top-up tax collected by another jurisdiction instead. Thailand’s own regime is designed to retain that taxing right.
Thailand’s expanding international tax transparency framework
The GloBE agreement adds to information channels Thailand already operates or is preparing to introduce. Thailand has exchanged financial account information under the Common Reporting Standard (CRS) since 2023.
Separately, from 1 January 2024 the Revenue Department tightened its treatment of foreign-source income: Thai tax residents can no longer avoid tax simply by delaying remittance to a later year, though income earned before 2024, or while non-resident, keeps its previous treatment.
Further changes are coming, with Thailand committed to implementing the Crypto-Asset Reporting Framework (CARF) from 2028 alongside a revised CRS framework. These measures are unfolding alongside Thailand’s ongoing OECD accession process, under which 25 OECD committees are currently examining Thai legislation, regulations and practices against international standards, tax transparency being one part of that wider review.
Practical implications
For most businesses in Thailand, the GloBE MCAA changes nothing directly. Its scope is confined to multinational groups above the EUR 750 million threshold, and it has no bearing on personal tax for foreign employees, retirees or other individual residents.
For groups within scope, the agreement is a reminder to revisit how existing BOI or other incentive arrangements interact with the 15% minimum rate, since Thailand’s position will increasingly be assessed against information shared internationally.
More broadly, the signing fits a clear pattern rather than standing alone. In a short period, Thailand has extended automatic financial account exchange, tightened foreign-source income rules, introduced a domestic minimum tax and now joined GloBE information exchange, with crypto-asset reporting to follow from 2028.
