Prevention of Tax Treaty Abuse – Fourth Peer Review Report on Treaty Shopping

Thailand

A. Progress in the implementation of the minimum standard

Thailand has 61 tax agreements in force as reported in its response to the Peer Review questionnaire. None of those agreements, comply with the minimum standard.

Thailand has not signed the MLI.

Thailand indicated in its response to the Peer Review questionnaire that steps have been taken (other than under the MLI) to implement the minimum standard in its agreements with Netherlands and Norway.

Thailand indicated in its response to the Peer Review questionnaire that it intends to join the MLI. Thailand indicated and that its internal process of approving the MLI is ongoing and that it expects to be able to sign the MLI in early 2022.

In its response to the Peer Review questionnaire, Japan indicated that its agreement with Thailand did not give rise to material treaty shopping concerns for Japan.

B. Conclusion

Thailand has developed a plan for the implementation of the minimum standard in its agreements with Armenia, Australia, Austria, Bahrain, Belarus, Belgium, Bulgaria, Canada, Chile, China (People’s Republic of), Czech Republic, Denmark, Estonia, Finland, France, Germany, Hong Kong (China), Hungary, India, Indonesia, Ireland, Israel, Italy, Japan, Korea, Luxembourg, Malaysia, Mauritius, New Zealand, Oman, Pakistan, Poland, Romania, Russian Federation, Seychelles, Singapore, Slovenia, South Africa, Spain, Sri Lanka, Sweden, Switzerland, Turkey, Ukraine, United Arab Emirates, United Kingdom, and Viet Nam. Thailand indicated in its response to the Peer Review questionnaire that it intends to sign the MLI in early 2022 and to list most of its agreements to be covered under the MLI.

Summary of the jurisdiction response - Thailand

 

	1.Treaty partners	2. Compliance with the standard	3. Signature of a complying instrument	4. Minimum standard provision used
1	Netherlands	No	No
2	Norway	No	No
3	United States	No	No	D-LOB

Other agreements

 

	1.Treaty partners	2. Inclusive Framework member
1	Armenia	Yes
2	Australia	Yes
3	Austria	Yes
4	Bahrain	Yes
5	Bangladesh*	No
6	Belarus	Yes
7	Belgium	Yes
8	Bulgaria	Yes
9	Cambodia*	No
10	Canada	Yes
11	Chile	Yes
12	China (People's Republic of)	Yes
13	Chinese Taipei*	No
14	Cyprus*	No
15	Czech Republic	Yes
16	Denmark	Yes
17	Estonia	Yes
18	Finland	Yes
19	France	Yes
20	Germany	Yes
21	Hong Kong (China)	Yes
22	Hungary	Yes
23	India	Yes
24	Indonesia	Yes
25	Ireland	Yes
26	Israel	Yes
27	Italy	Yes
28	Japan	Yes
29	Korea	Yes
30	Kuwait*	No
31	Lao People’s Democratic Republic*	No
32	Luxembourg	Yes
33	Malaysia	Yes
34	Mauritius	Yes
35	Myanmar*	No
36	Nepal*	No
37	New Zealand	Yes
38	Oman	Yes
39	Pakistan	Yes
40	Philippines*	No
41	Poland	Yes
42	Romania	Yes
43	Russian Federation	Yes
44	Seychelles	Yes
45	Singapore	Yes
46	Slovenia	Yes
47	South Africa	Yes
48	Spain	Yes
49	Sri Lanka	Yes
50	Sweden	Yes
51	Switzerland	Yes
52	Tajikistan*	No
53	Turkey	Yes
54	Ukraine	Yes
55	United Arab Emirates	Yes
56	United Kingdom	Yes
57	Uzbekistan*	No
58	Viet Nam	Yes