The Organisation for Economic Co-operation and Development (OECD) has mandated a Global Minimum Tax (GMT) of 15% applicable to multinational corporations with consolidated annual revenues exceeding €750 million (approximately THB 28 billion). Previously, many of these corporations enjoyed preferential tax treatments offered by host countries, often resulting in an effective tax rate below 15%.
To address these discrepancies, the OECD now allows either the host country of investment or the parent company’s home country to levy additional taxes to meet the 15% threshold. Consequently, countries worldwide—including Thailand—are enacting laws to ensure compliance with this rule. The Thai Ministry of Finance has introduced a new law, the Emergency Decree on Top-up Tax, B.E. 2567 (2024), which took effect on January 1, 2025.
Currently, approximately 1,500 multinationals benefiting from investment incentives in Thailand, including about 100 large Thai corporations, fall under this legislation. Simultaneously, countries have begun rolling out compensatory measures to mitigate the impact of the Global Minimum Tax in various forms.
Most recently, Mr. Narit Therdsteerasak, Secretary-General of the Thailand Board of Investment (BOI), announced that the BOI has approved amendments to investment promotion laws, introducing a new incentive: the “Qualified Refundable Tax Credit” (QRTC). This move aims to enhance Thailand’s competitiveness in attracting foreign direct investment under the OECD tax regime.
The QRTC is a credit based on investments and expenditures that enhance national competitiveness, such as research and development (R&D), innovation, high-skill workforce development, and investments in digital technology, automation, and sustainability initiatives. These credits can be refunded in cash within four years in accordance with criteria set by the BOI. The QRTC is designed to help offset the impact of supplemental tax collection and improve business liquidity.
TISCO Securities views this development as a positive for Thai equities previously affected, directly or indirectly, by the GMT. Key beneficiaries cited include Delta Electronics (Thailand) Public Company Limited (SET: DELTA), Gulf Development Public Company Limited (SET: GULF), B.Grimm Power Public Company Limited (SET: BGRIM), CH. Karnchang Public Company Limited (SET: CK), Amata Corporation Public Company Limited (SET: AMATA), WHA Corporation Public Company Limited (SET: WHA), Thai Union Group Public Company Limited (SET: TU), and i-Tail Corporation Public Company Limited (SET: ITC).
Moreover, Krungsri Securities (KSS) added that the Thai stock market had moved past its “sell on fact” phase after Thailand reached a trade agreement with the United States. Among the positive factors is Thailand’s 19% tariff rate, which is slightly lower than key competitors such as India, Brazil, and Vietnam.
At the same time, as of the morning of August 4, the Thai baht appreciated to THB 32.45 per US dollar, signaling improved stability and positioning Thailand as an attractive destination for foreign fund inflows in coming periods.
Looking ahead, the SET index is expected to trend sideways, with key investment themes favoring stocks poised to benefit from an easing interest rate environment—such as utilities, hire-purchase companies, high-yield dividend plays, REITs, and infrastructure funds.
KSS also recommends stocks set to benefit from a stronger baht, as well as those with positive momentum following Thai Airways’ (SET: THAI) trade resumption in the market and large-cap banks like Krung Thai Bank (SET: KTB) and Bangkok Bank (SET: BBL), along with infrastructure stocks like Airports of Thailand (SET: AOT).
Top picks include Gulf Development (SET: GULF), Krung Thai Bank (SET: KTB), and Muangthai Capital (SET: MTC).
