Thailand signed and ratified the Multilateral Instrument (MLI) to modify existing tax treaties to contain the equivalent of Article 25 of the OECD Model Tax Convention (OECD, 2017). Tax treaties have been modified to fulfil the requirements under the Action 14 Minimum Standard.
Making Dispute Resolution Mechanisms More Effective – Consolidated Information on Mutual Agreement Procedures 2023
OECD/G20 Base Erosion and Profit Shifting Project
Thailand
Recent developments relating to MAP in Thailand prior to 15 August 2023
Developments relating to MAP in the tax treaty network
Other developments relating to MAP
Thailand has published the Map Guideline on 2021 and the Guideline on APA process on 2022 which include roll-backs.
Latest Action 14 Peer Review report
13 September 2022 - https://doi.org/10.1787/18aa2039-en
Tax treaty network of Thailand
61 treaties, applicable to 61 jurisdictions (covering all treaties signed, although not necessarily in force)
status of MLI: in force.
Table 1. State of play of Thailand's tax treaty network
Source: OECD
Thailand's MAP programme
Organisation of competent authority function
five persons:
one head of unit
four persons working on MAP cases (all of which also work on other tasks as well).
contact persons for MAP requests:
Mr.Lavaron Sangsnit, Director-General, The Revenue Department of Thailand, 90 Soi Phaholyothin 7, Phaholyothin Road, Phayathai, Bangkok 10400
Tel. (+66) (2) 272 8639 E-mail address: MAPThailand@rd.go.th
Figure 1. Competent Authority Organisational Structure
Source: OECD
Table 2. Guidance on the MAP process
Overview of Thailand's MAP Statistics for 2022
Please refer to https://www.oecd.org/tax/dispute/map-statistics-thailand.pdf for details with respect to Thailand's MAP Statistics.
Figure 2. Cases Closed in 2022
Source: OECD
Figure 3. Evolution of Thailand's MAP caseload (2017-22)
Source: OECD
Table 3. Overview of Thailand’s MAP caseload for 2022
Source: OECD
Table 4. Thailand’s average time to resolve MAP cases in 2022
Source: OECD