As Private Enterprise and Family Office professionals, we believe that private companies, family offices and trusts are important contributors to the economic, environmental and social health of their economies.

The implementation of the OECD’s BEPS Pillar Two rules and the potentially complex multi-jurisdictional reporting requirements that accompany these rules may affect private companies, family offices and trusts, that may unwittingly be caught in the rising tide of international taxation.

It has been assumed that the Pillar Two rules and the global minimum tax rate will apply primarily to large, public multinationals, however, the specific application and scoping rules and how they will be applied to large privately owned businesses, family offices and trusts is not yet clear.

Are private companies, family offices and family trusts that meet the minimum threshold and that have a foreign presence included in the 'multinational enterprise' definition?

The tax and regulatory environment is constantly evolving and as tax professionals, it is our opinion that private companies family offices and trusts begin to review their structures and take action in anticipation of these changes.


We welcome your thoughts on the proposition we have put forward and other issues and opportunities that you believe are important to consider.

We want to hear your views and encourage you to contact us at or through your local KPMG Private Enterprise Tax professional.

We are committed to keeping the dialogue open with regular updates on the views of entrepreneurs, private business leaders and family office professionals like yourself on the KPMG Private Enterprise Tax website.

Why work with KPMG in Thailand

KPMG in Thailand, with more than 2,000 professionals offering Audit and Assurance, Legal, Tax, and Advisory services, is a member firm of the KPMG global organization of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee.