Thailand

On 19 September 2024, Thailand signed the letter of intent to join as a party in the Multilateral Convention to Facilitate the Implementation of the Pillar Two Subject to Tax Rule (STTR MLI). The Subject to Tax Rule (STTR) is a treaty-based rule that allows source countries to impose an additional withholding tax (WHT) on certain outbound intra-group payments that are subject to a normal tax rate of less than 9% in the country of the recipient. A wide range of payments between connected persons are targeted by the rule, including interest, royalties, and service fees. There is a notable exclusion in the case of dividends.