Thailand - BOI relief measures granted to alleviate the impact of the global minimum tax

In anticipation of Pillar Two regulations to be released by the Thai Revenue Department, the Board of Investment of Thailand (BOI) has announced relief measures to alleviate the impact of the global minimum tax that is expected to be implemented in 2025. However, the BOI relief measures take effect immediately for both existing BOI companies and new BOI applicants with consolidated group revenue of EUR 750 million (THB 28,000 million) or more. Accordingly, all multinational enterprises (MNEs) falling within the scope of country-by-country reporting will likewise be impacted by the 15% global minimum tax.

The key conditions and criteria mentioned in the BOI announcement are as follows:

Rights and incentives

BDO insight

Thailand is a signatory to the OECD Inclusive Framework and the Thai Cabinet already confirmed in March 2023 that the country will adopt Pillar Two, with legislation expected to be announced by the end of 2023 and the new measures implemented in 2025. Meanwhile, and in anticipation of Pillar Two regulations to be issued by the Revenue Department, the BOI has already issued measures that qualifying BOI-promoted entities can avail of to minimise the impact of Pillar Two. Potentially affected companies should begin to evaluate which incentive option would be more beneficial and plan accordingly.


Ishan Shah
BDO in Thailand