Insights

The rapid shift toward hybrid and remote work has created a complex challenge for multinational enterprises: when does an employee’s home office create a taxable presence, or Permanent Establishment (PE), in another country? The recent 2025 OECD report addresses this head-on, providing much-needed clarity through revised commentary on Article 5 (Permanent Establishment or PE). For businesses with cross-border talent, these changes offer a more practical framework for assessing tax exposure in jurisdictions where employees may be working remotely.

At the start of every year, the same urgency kicks in: "We need someone now." A resignation lands, a new project begins, a headcount is approved - and suddenly, we're back on the treadmill of reactive hiring. But what if 2026 is the year we stop doing that? Not long ago, I was speaking with the COO of a regional industrial group in Thailand. His team had just made two senior hires where both came with strong profiles, ticked the usual boxes and six months in, were underwhelming.

The Thai Revenue Department (TRD) sets higher tax collection targets each year, increasing pressure on both the tax authority and taxpayers. The TRD is accelerating its transformation towards an AI-enabled, data-driven administration to enhance operational effectiveness and improve overall tax collection.

As the year closes, leadership teams across Thailand are finalising their 2026 strategies - refining targets, outlining transformation plans, and setting bold growth ambitions. But amid all this planning, one critical question often gets overlooked: Are the people who will carry this strategy into 2026 the right ones to do it? In my recent conversations with CEOs and CHROs, the answers to this question are rarely clear. Many leaders think they’ve got the right team - but they haven’t pressure-tested that belief. The world is changing fast, and the leadership qualities required even two years ago may not match what’s needed next year.

This tax news will be of interest to: Thai companies that are part of multinational enterprise (MNE) groups and engage in intercompany transactions. Introduction The Thai Revenue Department (TRD) has implemented an artificial intelligence (AI)–driven big data analysis system to improve operational efficiency, review taxpayers’ data, and assess potential risk areas or red flags. The system classifies taxpayers as either “good” or “risky”. If potential red flags are detected, the system notifies the TRD to consider initiating a tax audit. You may refer to our transfer pricing (TP) series Part 1: Potential Red Flags. In addition, the TRD has recently launched the QUICK BIG WIN scheme, which allows eligible taxpayers to receive tax refunds within a significantly shortened timeframe and without undergoing a tax audit if they meet the scheme’s criteria. This aims to enhance taxpayer liquidity and support business operations.

In recent months, I’ve written about what it takes to create real momentum within organisations: how leadership, structure, process, and culture each play a role in determining whether the strategy translates into performance. But as we enter the final quarter of the year, I find myself reflecting on something even more fundamental.

This tax news will be of interest to: Thai companies that are part of multinational enterprise (MNE) groups and engage in intercompany transactions. In our Part 3: we have provided guidance on how companies can minimise risks during a tax/TP audit related to intra-group services, as well as examples of evidence and supporting documents. In this article, you will find guidance on how to minimise risk related to royalty transaction.

Last month, we talked about structure, how the way you organise your business should serve your strategy, not the other way around. But there’s something even more invisible, yet equally critical, shaping whether strategy turns into real results. And that is culture.

Thailand’s newly amended Organic Act on Anti-Corruption (No.2) B.E. 2568 (2025) marks a significant shift in corporate compliance expectations. With expanded whistleblower protections and stricter enforcement mechanisms, companies operating in Thailand must act swiftly to align their internal controls and reporting systems with the new legal landscape.

Cloud & Software Services and Withholding Tax: Where Does Thailand Draw the Line?

Last month, I wrote about how the right leaders, those who truly move the needle, are rarely out there looking for jobs, but they are always listening for the right opportunity. Attracting such high-impact leaders is a powerful step forward, but it is only half the battle. Once those leaders join, the real question emerges: is your organisation designed to let them succeed?

This tax news will be of interest to: Thai companies that are part of multinational enterprise (MNE) groups and engage in intercompany transactions. In the TP series Part 1 & Part 2: we have highlighted the potential red flags and how to deal with transfer pricing (TP) audit. The main focus of the Thai Revenue Department (TRD) is on intra-group services, which we will cover in this article.

In Thailand’s fast-moving business environment, one truth is quietly shaping the success of transformation and growth: the leaders who can truly move the needle, those who can drive change, inspire teams, and navigate complexity, are rarely the ones applying for roles. They’re not browsing job boards. They’re not polishing their resumes. They’re deep in the business of leading. But they are listening for the right opportunity, at the right moment, delivered by someone they trust.

Global Business in a New Risk Landscape Given the present level of technological development and economic volatility around the world, businesses are operating under immense pressure from all sides.

Not long ago, in a meeting with a group of senior executives here in Bangkok, I noticed something interesting. While everyone was talking about Generative AI, the opportunities, the fears, the future, very few were talking about leadership. How will we, as executives, actually lead in a world transformed by AI? It struck me that while AI advancing at incredible speed, leadership thinking must move even faster. This is not just another business trend. It is a profound shift - one that challenges how we define value, build teams, and set strategy. Here are a few thoughts I wanted to share.

In May, we explored how leadership must evolve in Gen AI. This month, I want to shift our focus to something equally fundamental but often ignored in transformation conversations: process. It's not technology, platforms, or automation. It's just a simple, clear human process, the way work actually happens, from the ground up.