Extension of filing deadline for country-by-country report

Under Notification of the Director-General of the Revenue Department on Income Tax No. 408 (“Notification No. 408”) dated 30 September 2021, multinational enterprises (“MNE”) required to submit a country-by-country report (“CbCR”) in Thailand must file the CbCR together with the annual corporate income tax return (Form PND 50) within 150 days of the end of the accounting period.

Keywords: Mazars, Thailand, Tax, MNE, CbCR, PND 50, Corporate income tax

8 February 2022

However, a notification issued by the Ministry of Finance on 23 December 2021 extended the filing deadline, as follows:

within 12 months of the closing date of the accounting period for the Ultimate Parent Entity (“UPE”) and qualified Surrogate Parent Entity (“SPE”) located in Thailand, under Clause 2 (1) and Clause 4 of Notification No. 408; and
within 60 days of the date of receipt of the notice to file a CbCR from the Revenue Department for an entity conducting business in Thailand which is neither the UPE nor the SPE, but which is required to file a CbCR in Thailand if one of the following criteria is met, under Clause 2 (2) of Notification No. 408:

(a) the UPE is not required to file the CbCR in its country of tax residence;

(b) the UPE’s country of tax residence does not have a Multilateral Competent Authority Agreement (“MCAA”) on automatic exchange of information with Thailand effective in the accounting period in which the CbCR shall be filed; or

The extension is applicable to CbCRs to be filed for the accounting period starting on or after 1 January 2021.