Insights

Thailand’s position on Article 12 (Royalties) of the recent 2025 OECD report reflects a robust commitment to source-based taxation for cross-border payments. Unlike the OECD’s preferred move towards residence-based taxation for royalties, Thailand continues to advocate for the right of the state where the income arises to collect tax. By expanding the definition of royalties and establishing clear source rules, Thailand ensures that a broad spectrum of payments for technology, equipment, and expertise remains subject to local withholding tax.

The Royal Thai Government Gazette has announced the Labour Protection Act (No. 9), B.E. 2568 (2025) (“Amendment No. 9”), which amends key provisions under the Labour Protection Act B.E. 2541 (1998) (“Labour Protection Act”). The amendments are effective from 7th December 2025 introduce new protections, leave entitlements and employer compliance requirements.

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.

Grant Thornton recorded USD 8 billion in global revenues for the year ending 30 September 2024, marking an 8.8% growth in constant currency. This achievement reflects the network’s commitment to quality, innovation, and sustainability, even amid global economic volatility and geopolitical challenges.

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.

PRESS RELEASE Grant Thornton Specialist Advisory Services Co., Ltd. appointed as the interim executive of JKN Global Group Public Company Limited

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.

Thailand stands at a crossroads. Once powered by a young and growing population, the country now faces fewer births, a rising elderly population, and a rapidly shrinking workforce. This is not a distant problem but one already reshaping the economy, society, and future of the nation. The question is not when the demographic crisis will occur, but whether Thailand can adapt quickly enough to survive.

Business leaders in Thailand are navigating a climate of uncertainty. Many trust the strength of their own companies, but confidence in the national economy has weakened. Political disruption, tariffs, and regional tensions have left the outlook fragile and the future unclear.

Thailand is facing a rising threat to its future workforce. Brain drain, the movement of skilled people abroad for better pay, opportunities and quality of life is easier than ever in a globalised world, and its effects on Thailand are already visible. As younger generations enter the job market, society and workplaces must recognise their changing needs and respond appropriately, as coupled with the country’s demographic pressures, the need to keep and grow a strong workforce has never been greater. The question is clear, will Thailand make the changes needed to reverse brain drain, or will it keep watching its skills slip away.

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?