OECD Inclusive Framework (Pillar One)
OECD Inclusive Framework on BEPS is the multilateral tax-coordination forum for OECD and G20 base-erosion and profit-shifting reforms. Its Pillar One Amount A architecture reallocates taxing rights for the largest multinational enterprises above the global revenue and profitability thresholds, including digital and consumer-facing groups. For Thailand, the framework is relevant to permanent-establishment risk, digital-services taxation, transfer-pricing exposure, and revenue-allocation analysis for cross-border platform operators.
Snapshot
Headline numbers a buyer checks first.
Member jurisdictions
145+
2024
Pillar One MNE revenue threshold
EUR 20B
2024
Pillar Two global minimum tax rate
15%
2024
Thailand BEPS implementation
Pillar Two draft law 2025
2025
Profile overview
OECD Inclusive Framework on BEPS is the multilateral tax-coordination forum for OECD and G20 base-erosion and profit-shifting reforms. Its Pillar One Amount A architecture reallocates taxing rights for the largest multinational enterprises above the global revenue and profitability thresholds, including digital and consumer-facing groups. For Thailand, the framework is relevant to permanent-establishment risk, digital-services taxation, transfer-pricing exposure, and revenue-allocation analysis for cross-border platform operators.
Programs administered
Pillar One
Amount A — taxing-rights reallocation
Reallocates taxing rights for MNEs with global revenue above USD 20B and profitability above 10%. Applies to digital and consumer-facing sectors. ~100 MNEs globally expected in scope; Thailand receives allocation as a market jurisdiction.
Pillar Two
Global minimum tax — 15% IIR/UTPR
Establishes 15% global minimum effective tax rate for MNEs with consolidated revenue above EUR 750M. Qualified domestic minimum top-up tax (QDMTT) framework allows host countries including Thailand to collect top-up tax domestically.
BEPS action plan
Transfer pricing, CbCR, PE rules
Oversees 15-action BEPS implementation including transfer-pricing documentation, country-by-country reporting (CbCR), hybrid mismatch rules, and digital permanent-establishment standards adopted by 140+ member jurisdictions.
Thailand linkage
Thai Revenue Department alignment
Thailand as BEPS Inclusive Framework member aligns Revenue Department rules on CbCR, transfer-pricing documentation (Section 71bis), and is studying QDMTT adoption timetable.
Pillar Two scope — illustrative Thailand-relevant MNE groups
EUR 750M revenue threshold; Pillar Two applies to in-scope groups with Thai operations
Google / Alphabet
Sector
Digital advertising
Thai presence
Ad-revenue attribution
Pillar Two exposure
High — low Thai ETR on digital revenue
Toyota Group
Sector
Automotive manufacturing
Thai presence
Large Thai manufacturing
Pillar Two exposure
Medium — manufacturing ETR typically adequate
Sector
Life insurance
Thai presence
Licensed Thai subsidiaries
Pillar Two exposure
Low-medium — insurance ETR varies
| MNE group | Sector | Thai presence | Pillar Two exposure |
|---|---|---|---|
| Google / Alphabet | Digital advertising | Ad-revenue attribution | High — low Thai ETR on digital revenue |
| Toyota Group | Automotive manufacturing | Large Thai manufacturing | Medium — manufacturing ETR typically adequate |
| AIA / Prudential | Life insurance | Licensed Thai subsidiaries | Low-medium — insurance ETR varies |
| Lazada / Alibaba | E-commerce platform | Platform operations, logistics | High — platform ETR often below 15% |
Key drivers 2025-2026
QDMTT adoption
Thailand domestic minimum tax
Thailand Revenue Department studying qualified domestic minimum top-up tax adoption. Enactment would allow Thailand to collect top-up revenue domestically before other jurisdictions claim it.
Pillar One treaty
Amount A multilateral convention
Pillar One Amount A requires a new multilateral convention. Signing timeline and ratification progress are the critical path variable; delays push implementation past 2025.
BOI incentive review
Thai tax holidays vs Pillar Two
Thailand BOI tax holidays below 15% ETR create Pillar Two top-up exposure for qualifying groups. BOI and Revenue Department reviewing incentive-programme design to minimise leakage.
Where this profile is featured
Reports that reference this entity in their operator concentration or analysis.
Featured in
Pillar-2 Global Minimum Tax (15%): Multinational Readiness
International coordinator of Pillar-2 implementation across 140+ jurisdictions.
Featured in
Permanent Establishment Risk for Digital Businesses in Thailand
Pillar-1 amount-A overlay for >USD 20B digital MNEs.
Featured in
Thai Transfer Pricing and Country-by-Country Reporting (CbCR)
Pillar-1 amount-A overlay for >USD 20B digital MNEs.
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Reports featuring this profile
Pillar-2 Global Minimum Tax (15%): Multinational Readiness
International coordinator of Pillar-2 implementation across 140+ jurisdictions.
Open report →
Sits alongside 3 other Atlas profilesPermanent Establishment Risk for Digital Businesses in Thailand
Pillar-1 amount-A overlay for >USD 20B digital MNEs.
Open report →
Sits alongside 2 other Atlas profilesThai Transfer Pricing and Country-by-Country Reporting (CbCR)
Pillar-1 amount-A overlay for >USD 20B digital MNEs.
Open report →
Sits alongside 6 other Atlas profiles