Thailand: Extended deadlines for submitting country-by-country reports

The extensions are applicable for the fiscal year starting on or after 1 January 2021.

The extensions are applicable for the fiscal year starting on or after 1 January 2021.

The Thai Revenue Department in late December 2021 announced an extension of the deadlines for country-by-country (CbC) report submissions.

The tax department’s notification provides for the following deadlines:

  • Within 12 months of the fiscal year-end for the ultimate parent entity (UPE) and qualified surrogate parent entity (SPE) located in Thailand
  • Within 60 days upon request by the Thai Revenue Department for Thai associated enterprises of a foreign UPE that conducts business in Thailand if:
    • There is no requirement for the filing of a CbC report in the country where the UPE is a tax resident
    • The UPE’s country of tax residence does not have a Multilateral Competent Authority Agreement on the Automatic Exchange of Information (MCAA) with Thailand for the respective reporting period
    • There is an incident of automatic exchange systematic failure

The extensions are applicable for the fiscal year starting on or after 1 January 2021. 

KPMG observation

According to the notification, the CbC report filing deadlines in Thailand aim to align with international standards. However, a Thai reporting entity (a Thai UPE) may need to evaluate whether it meets the threshold of total consolidated group revenue (THB 28 billion in the previous 12-month accounting period), especially if the MNE group has never prepared consolidated financial data or statements.

With CbC report submissions, the tax authorities will have access to more financial data of not only taxpayers in Thailand but also taxpayers around the world within consolidated groups. Therefore, before submitting CbC reports, groups and companies operating in Thailand need to conduct tax and transfer pricing risk assessments, as well as prepare supporting documents and explanations in advance—especially if there may be tax and transfer pricing inquiries and audits by the tax authorities.

Read a January 2021 report prepared by the KPMG member firm in Thailand


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