The Taxing Rights Effect of Pillar Two Implementation on Thai Domestic Tax Laws

Abstract: Digitalisation and globalisation have significantly impacted daily life, including taxation, resulting in benefits and disadvantages. One major issue lies in the global context, where tax evasion and erosion have become prevalent issues. To address these challenges, the International Organization for Economic Co-operation and Development (OECD) has introduced a new set of rules known as Pillar Two. These rules aim to address the competition for attracting investors through a “race to the bottom” in tax rates by establishing a standardised Global Minimum Tax (GMT) rate of 15% to be applied to economic activities across jurisdictions. Thailand has recently announced its intention to incorporate these rules into domestic tax laws. Consequently, this thesis examined the implications of implementing Pillar Two on allocating taxing rights within the national legislative framework. The research utilised the dogmatic legal method to identify and analyse the current Thai tax system, Pillar Two model rules, and perspectives on implementation. The findings illustrated the most beneficial approach to allocating taxing rights to Thailand.