Thailand has adopted the OECD’s global minimum tax framework through the Emergency Decree on Top-Up Tax B.E. 2567 (2024). Published in the Government Gazette on December 26, 2024, this legislation implements a 15% global minimum effective tax rate for large multinational enterprise (MNE) groups. The emergency decree took effect on January 1, 2025. The emergency decree was enacted through expedited procedures to implement “pillar two” of the OECD’s Base Erosion and Profit Shifting (BEPS) 2.0 project’s Global Anti-Base Erosion (GloBE) Rules. This swift implementation ensures Thailand can collect relevant tax revenues and prevents potential revenue losses from MNEs that might otherwise shift profits to jurisdictions with lower tax rates or to countries that have already implemented similar top-up tax legislation. Key aspects of Thailand’s implementation of the global minimum tax through the emergency decree are described below. Top-Up Tax The emergency decree introduces a dual mechanism for collecting additional top-up tax from MNEs whose effective tax rate falls below 15%. The first mechanism is a domestic top-up tax that targets MNEs operating within Thailand when their local effective tax rate is lower than 15%. The second mechanism is the income inclusion rule, which determines when a company’s foreign income should be included in the parent (main) company’s taxable income. This rule applies to Thai-based entities—including ultimate parent entities (UPE), intermediate parent entities, and partially owned parent entities—that hold ownership stakes in low-tax foreign jurisdictions. Scope MNEs subject to Thailand’s implementation of the global minimum tax framework are defined in the emergency decree as those whose UPEs report consolidated revenue of at least EUR 750 million (approximately THB 28 billion) in at least two of the four accounting periods preceding the relevant fiscal year. Reporting and Payment In-scope MNEs must comply with specific reporting obligations to the Thai Revenue Department. The filing deadline is set

Following the enactment of the Tax Administration Law (TAL), Myanmar’s Ministry of Planning and Finance has issued Notification No. 44/2024, which outlines directives and procedures for addressing violations of tax law provisions. These procedures, which came into force on June 13, 2024, primarily focus on three key areas: tax evasion, impeding tax administration, and failure to preserve secrecy. The notification primarily aims to address tax evasion, impeding tax administration, and failure to preserve secrecy, classifying these offenses as either subject to arrest without warrant or not. Notably, tax evasion is classified as an offense subject to arrest without warrant, while impeding tax administration and failure to preserve secrecy are not. The notification also prescribed the forms for notifying taxpayers before taking any action. Tax Evasion Tax evasion refers to a taxpayer who willfully evades the assessment, payment, or collection of tax. Penalties for such offenses include fines of MMK 250,000 (approx. USD 120) or 100% of the evaded tax (whichever is greater), imprisonment for up to seven years, or both. The enforcement process for tax evasion requires the chief officer of the township revenue department or an officer in charge (the tax authority) to assess the relevant documents and information provided by the taxpayer. If a taxpayer is found to be evading tax, the tax authority must send a notice in the prescribed form for verification within 15 days. Taxpayers may apply for a one-time extension of 15 days to submit requested documents and make disclosures. If the taxpayer cannot fulfill the requirements as instructed, the tax authority will seek approval from the director general of the Internal Revenue Department (IRD) for criminal proceedings as cognizable offences. Impeding Tax Administration and Failure to Preserve Secrecy Impeding tax administration refers to obstruction or attempted obstruction of taxation staff or officers

In May and June 2024, Cambodia’s General Department of Taxation (GDT) issued two notable tax incentive packages that aim to encourage business growth in the country. The details of these incentives are outlined below. Tax Incentives for Expansion of Qualified Investment Projects The GDT’s May 10, 2024, regulation (Prakas No. 313 MEF. PrK. PD) provides income tax incentives for expansion of qualified investment projects (QIPs), including an income tax exemption for the following types of expansion: Expansion of existing production. Expansion through product line diversification within the same lines. Implementation of new technologies that enhance productivity or protect the environment. Other forms of expansion set out in future sub-decrees. The number of years for the income tax exemption depends on the investment activities of the QIP, in accordance with the business groupings provided in the Sub-Decree on the Implementation of the Investment Law in Cambodia—9 years for group 1, 6 years for group 2, and 3 years for group 3. After receiving approval for the QIP expansion from the Council for the Development of Cambodia (CDC) or one of its Provincial-Municipal Investment Sub-Committees (PMISs), the GDT will certify the income tax exemption period. The exemption begins on the date the enterprise first receives income from the QIP expansion. QIPs seeking this tax exemption need to declare the amount of money that they intend to use for the expansion. Once allowed, the company must use that money for construction materials or new production equipment before the expiration of the tax exemption period. The income tax exemption can be revoked if: The enterprise does not use the capital to expand the QIP by purchasing the construction material and new production equipment as requested for the expansion. The enterprise fails to invest the prescribed amount before the expiration of the tax exemption