In November 2024, Thai Prime Minister Paethongtarn Shinawatra unveiled ambitious plans to enhance tax incentives for foreign film productions during a networking reception in Los Angeles, coinciding with her visit to the APEC Economic Leaders’ Meeting in Lima, Peru. This event, attended by Motion Picture Association executives and leaders from top US film companies, marked a significant commitment to boosting foreign investment in Thailand’s film industry. Thailand’s Department of Tourism (DOT) prioritized the initiative by updating the Announcement on Guidelines, Procedures, and Conditions for Applying for Benefits Under the Incentive Measures for Foreign Film Production in Thailand in December 2024 to further position Thailand as a destination for large-scale international film and television productions. Key Amendments to Film Incentives under the 2024 Announcement The 2024 announcement introduced major changes, including (1) removal of the rebate cap, previously set at THB 150 million (approx. USD 4.5 million) per project, enabling rebates based on total qualified spending, and (2) an increase in cash rebate rates. The maximum allowable cash rebate rate was increased to 30 percent from the previous cap of 20 percent. The base rate of 15 percent remains unchanged. The primary incentive available under the 2024 announcement is a 15 percent cash rebate on qualified spending in Thailand of at least THB 50 million (approx. USD 1.5 million). On top of this primary incentive, additional incentives are available; however, the total possible cash rebate is capped at 30 percent, and the additional incentives can only amount to an added 15 percent. Also, the total rebate (including both primary and additional incentives) for films with a budget of less than THB 100 million (approx. USD 3 million) is capped at 25%. To obtain a higher rebate rate, productions may apply for the following additional incentives: Compliance Requirements Foreign production companies

On February 18, 2025, the Thai Senate approved an amendment to the Act on the Establishment of and Procedures for the Tax Court. This follows the July 2024 approval by the Thai cabinet and subsequent preparation of supporting secondary legislation. This important amendment to procedural law, once it takes effect, will extend the exclusive jurisdictional powers of the Tax Court to all criminal tax, customs, and excise tax claims in addition to the court’s existing jurisdiction over all such civil claims. The amendment, while now formally approved by the legislature, is awaiting the king’s signature and will take effect 180 days after its publication in the Government Gazette. Based upon its projected publication date, the amendment will likely take effect by the end of the third quarter of this year. This development is set to offer a more sophisticated Tax Court litigation process for highly specialized and often complex criminal tax and customs claims, something with which Thailand’s traditional criminal courts have struggled. It also ensures that all tax and customs matters are adjudicated before the same court, saving time, party costs, and judicial resources. This appears likely to result in more consistent adjudication of criminal tax and customs disputes, a benefit for the Thai government and party litigants alike. Any ongoing criminal tax and customs claims already commenced with the respective criminal courts on the date on which the amendment becomes effective will remain under the exclusive jurisdiction of those criminal courts. The Tax Court will have exclusive jurisdiction over all other claims. This important legislative change offers those managing or otherwise facing civil and/or criminal Thai tax or customs disputes the opportunity to more effectively plan and execute a uniform defense strategy before a single, qualified forum.

On February 20, 2025, the National Assembly of Vietnam made public the executed Resolution 170/2024/QH15, which outlines special mechanisms and policies to address difficulties and obstacles related to notable real estate projects and land issues in Da Nang, Ho Chi Minh City, and Khanh Hoa Province. This resolution, with an effective date of April 1, 2025, aims to resolve issues identified in inspection conclusions, audits, and court judgments, including 1,313 cases of land-use term violations in Da Nang. Solutions Resolution 170 provides a variety of mechanisms and policies to clear the way for projects to proceed with implementation. These may include, depending on the specific location, the following solutions. For issued Land Use Rights Certificates (LURC) that violate the land-use term for business production land in Da Nang: For projects that have already been invested in and utilized, the land-use terms in the LURC may be adjusted to 50 years from the date of the decision on land allocation, land lease, conversion of land use purpose, or actual land handover. For continued use of land, determining land prices, and calculating land use fees and land rental fees applicable to a list of projects in Da Nang, Ho Chi Minh City, and Khanh Hoa Province: The city/provincial People’s Committees will review and complete, within their authority, the procedures related to land, investment, construction, environment, and forestry of such projects in accordance with the current laws. Projects that meet legal and regulatory requirements after thorough review and compliance checks will be allowed to continue, provided they are aligned with urban planning, environmental standards, and national security requirements. In addition, investors must fulfill applicable financial obligations, including land use fees and land rental payments, which will be reassessed and collected based on the land price tables applicable in Da Nang, Ho Chi

As Vietnam continues its government restructuring, including the merging of several key ministries, the country is signaling that mergers of provinces could be next. Conclusion 126-KL/TW of the Politburo and Secretariat, issued on February 14, 2025, sets out several tasks for continuing to streamline the political system in 2025, notably including, among others, the following: Elimination of intermediate administrative levels, and mergers of provincial units: The Government Party Committee is tasked with researching and planning for the elimination of intermediate administrative levels (district levels); reorganizing the commune level with structures, functions, duties, powers, and responsibilities aligned with the new organizational model; and proposing the merging of some provincial administrative units. A report to the Politburo is required by Q3 2025. Reorganization of police structure: The Central Public Security Party Committee is tasked with leading and coordinating the implementation of a three-tier police organization, eliminating the district-level police. Judicial system reforms: The Central Party Committees of the Supreme People’s Court and the Supreme People’s Procuracy are tasked with researching and advising on the organizational model for courts and procuracies, and proposing amendments and supplements to relevant party mechanisms and state laws, with the aim of eliminating the district level. A report to the Politburo is required by Q2 2025. Implications of Merging Provinces The merging of provinces could bring positive impacts as well as new challenges. The expected benefits include: Administrative efficiency and cost saving: Reducing the number of administrative units could lead to more efficient governance and decision-making processes, as well as lower administrative costs due to fewer government offices and personnel. Economic development: Larger administrative areas can benefit from better allocation of resources and infrastructure development. Larger provinces may also attract more investment due to increased economic potential and market size. Improved service delivery: Public services could improve