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

 

The KPMG name and logo are trademarks used under license by the independent member firms of the KPMG global organization. KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.