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In Thailand’s Country-by-Country Reporting (CbCR) system, a Notification and a report submission are two separate steps. The Notification tells the Revenue Department about the group and its reporting entity. Completing it does not file the report. [1]
What is CbCR?
Country-by-Country Reporting gives tax authorities a breakdown of a multinational group’s revenue, profit, tax and activity in each country. They use it to assess transfer pricing and profit-shifting risk. [2]
Which revenue figure counts?
Thailand’s test uses the group’s consolidated revenue for the preceding accounting period. The threshold is THB 28 billion. [3][4]
The Thai company’s own revenue does not decide this. For a calendar-year FY2025 report, look at the group’s FY2024 consolidated revenue. A Thai subsidiary should confirm that figure with head office, even if its own revenue is far below the threshold. [5]
If the group reports in a foreign currency, convert the revenue to baht at the Bank of Thailand’s average bank buying rate for money transfers on the last day of the preceding period. Notification 408 sets fallback rates if that rate is not available. If the preceding period was shorter than 12 months, the threshold is reduced in proportion to the number of days. [3][5]
If the group’s UPE is resident outside Thailand, its home jurisdiction has a threshold near the January 2015 equivalent of EUR 750 million, and the group is below that threshold, exchange-rate movements alone do not bring it into Thai CbCR reporting. This protection depends on those conditions. It is not an exemption for every foreign-parented group. [5]
Who files in Thailand?
The main Thai reporting entities include:
- The group’s Ultimate Parent Entity (UPE), if it is established under Thai law.
- A Surrogate Parent Entity (SPE): a group entity established under Thai law that the UPE has appointed to report on its behalf and that meets the conditions in Clause 4 of Notification 408. [2][3]
A Thai subsidiary of an overseas group is in a different position. The OECD’s 2026 review, published on 19 October 2026, records Thailand’s local filing requirement as suspended and surrogate parent filing as permitted. [4] That describes the rules as reviewed. It is not a conclusion about any one company.
The Thai finance team should still ask the group tax team who files the report, in which country, and whether the Thai Notification has been completed. If the Revenue Department sends a submission notice under Clause 2(2), check the requirements and the 60-day deadline straight away.
When is the FY2025 report due?
A Thai UPE or SPE generally files within 12 months after the end of the reporting year. [1][6] Worked example: for a year ending 31 December 2025, 12 months later is 31 December 2026. A group with a different year-end should work out its own date.
Separately, under Clause 2(2) of Notification 408, a company doing business in Thailand that receives a submission notice from the Revenue Department has 60 days from the date it receives that notice. This is different from the general 12-month deadline above, and it does not change the OECD-recorded suspension of local filing. [5][6]
How do Notification and submission differ?
A Notification tells the Revenue Department about the group and its reporting entity. A representative group company states the reporting entity’s jurisdiction and type, and uploads a list of group companies doing business in Thailand. The submission is the report itself, prepared in English in the OECD CbCR XML format. [1]
The Notification has its own deadline, which falls earlier than the report’s. Check the Revenue Department’s guidance for the date that applies to your group. [5]
The main steps are:
- Arrange access to the Revenue Department’s CbCR system.
- Complete the Notification and check the details.
- Submit the report in English, in the OECD CbCR XML format.
- Check that the submission was successful and retain the filing receipt. [5]
A completed Notification does not show that the report has been filed. Confirm that the reporting entity has submitted it.
What should the Thai subsidiary ask head office?
Start with these four items:
- The UPE’s name and tax jurisdiction.
- The reporting year and the group’s consolidated revenue for the preceding year.
- The reporting entity, the filing country and a contact person.
- The Notification status, the Thai entities covered and any filing evidence.
Agree who handles each step and which documents are still missing.
