Thailand: Additional country-by-country reporting submission requirements

New submission requirements for country-by-country (CbC) reporting

New submission requirements for country-by-country (CbC) reporting

Guidance from the Thai Revenue Department adds new submission requirements for country-by-country (CbC) reporting.

Notification of the Director-General (D.G.) No. 419 (12 January 2022) added the following new provisions to the CbC reporting requirements: 

  • The “reporting entity” must register for e-filing for CbC reporting purposes via one of two e-filing systems.
  • After receiving approval from one of the two e-filing systems, the reporting entity can use the username and password provided by that system to file the CbC report.
  • The CbC report will be considered as having been successfully submitted when the reporting entity receives the “acceptance confirmation” from the e-filing system. 

KPMG observation

The e-filing systems for CbC reporting are currently available for registration, and the Thai Revenue Department has provided guidance for the registration and submission process.  

Thai reporting entities—including a Thai ultimate parent entity and an overseas multinational entity (MNE) group that is considering appointing a Thai associated enterprise as its surrogate parent entity in Thailand—need to consider and evaluate whether the filing threshold has been met, especially if the MNE group has never prepared consolidated financial data or statements.

It is important to highlight that with a CbC reporting submission, the tax authorities will have access to more financial data, not only of taxpayers in Thailand but also of taxpayers around the world within consolidated groups. Therefore, before making a CbC report submission, MNE groups and companies operating in Thailand need to consider conducting tax and transfer pricing risk assessments, as well as preparing supporting documents and explanations in advance—especially if there may be tax and transfer pricing inquiries and audits by the tax authorities.

Read a February 2022 report prepared by the KPMG member firm in Thailand


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