Extension of filing deadline for country-by-country report
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
(c) There is an incident of data exchange failure.
The extension is applicable to CbCRs to be filed for the accounting period starting on or after 1 January 2021.