Thailand Gazettes Royal Decree Amending Provisions of Additional Tax Act to Implement Pillar 2

The Thai Official Gazette Dec. 26 published a Royal Decree introducing the Pillar Two Global Minimum Tax for large multinational enterprises (MNEs), as provided under the OECD/G20 base erosion and profit shifting (BEPS) project. The decree includes measures: 1) clarifying relevant definitions and tax calculation procedures; 2) imposing a 15 percent minimum global effective tax rate (ETR) on MNEs with annual consolidated revenue of at least 750 million euros (US$781.9 million) in two or more of the last four accounting periods; 3) introducing a minimum top-up domestic tax for in-scope group members; 4) allocating additional tax revenue in accordance with ...