Thailand Rolls Out Refundable Tax Credits to Offset Global Minimum Tax and Woo Investors

Thailand is proactively bolstering its economic competitiveness on the global stage, introducing significant measures to attract foreign investment and foster domestic innovation. This strategic shift comes as the Organisation for Economic Co-operation and Development (OECD) implements a new global minimum tax rule.

The OECD’s framework mandates a 15% minimum effective tax rate for multinational corporations with annual revenues exceeding €750 million (approximately 28 billion baht). To comply, Thailand’s Ministry of Finance enacted the Emergency Decree on Top-Up Tax B.E. 2567, effective January 1, 2568 (2025), impacting approximately 1,500 promoted multinational companies and 100 large Thai firms.

To counteract potential deterrents from this new tax, the Board of Investment (BOI) is introducing a “Qualified Refundable Tax Credit (QRTC).” This OECD-recognised tool allows companies to convert eligible investments and expenses—such as those in research and development, innovation, high-skilled personnel development, digital technology, and sustainability—into tax credits. These credits can be used to pay various taxes, including the new top-up tax, and any remaining balance can be refunded in cash within four years.

This initiative aims to preserve Thailand’s competitive edge, enhance business liquidity, and stimulate continuous investment in high-value activities. BOI Secretary-General Narit Therdsteerasak highlighted that these reforms, especially the QRTC, will instill confidence in global investors amidst the evolving international tax landscape. Coupled with startup support, Thailand is poised to attract quality investment, nurture high-tech industries, and secure sustainable economic growth.

 

Prior to this announcement, the market speculated these following securities to be impacted by the OECD’s GMT due to their low effective rates: Delta Electronics (Thailand) (SET: DELTA), Thai Union Group (SET: TU), Gulf Development (SET: GULF), Banpu Power (SET: BPP), Electricity Generating (SET: EGCO), B.Grimm Power (SET: BGRIM), Global Power Synergy (SET: GPSC), Ratch Group (SET: RATCH) and Regional Container Lines (SET: RCL).

 

Tisco Securities (TISCO) expected stocks such as DELTA, GULF, BGRIM, CK, AMATA, WHA, TU and ITC to benefit from this development.