The Thai Board of Investment Announces Continued Tax Incentives Aligned with Global OECD Minimum Tax and Introduces FastPast Mechanism

In November 2025, the Board of Investment reaffirmed that all existing tax incentives will remain in place despite the new OECD global taxation rule shifts. This signals policy continuity for investors with current BOI promotion certificates. This commitment comes as Thailand implements the OECD's 15% global minimum tax requirement through the Emergency Decree on Top-Up Tax, which is effective from January 1, 2025. This Decree applies to multinational enterprises with consolidated group revenues exceeding €750 million.​

The BOI has announced that it will prepare a new tax incentive package for companies that would be subject to the OECD threshold. The Thai Cabinet has approved a Qualified Refundable Tax Credit (QRTC) mechanism specifically designed to comply with OECD Pillar Two rules. QRTCs function fundamentally differently from traditional tax incentives: they are treated as income for tax purposes rather than reducing covered taxes (essentially like cash vouchers for specific investments), resulting in higher effective tax rates that minimize top-up tax exposure while delivering substantive incentive value. Credits targeting research and development, advanced skills development, production efficiency, and sustainable investment are offered at rates of 30% to 50% of qualifying expenditures, with unused credits refundable in cash. The implementation of the QRTC is expected to be administered jointly by the BOI and the Thai Revenue Department in 2026 once it is finalised.

To complement the tax incentives, the Cabinet has also approved the introduction of Thailand´s FastPass mechanisms to address regulatory bottlenecks that are blocking investment execution. The FastPass mechanism currently targets 70 high-profile projects worth 300 billion baht. FastPass coordinates seven government agencies and aims to reduce approval and licensing times by 20 to 50%. Regulatory approvals and expedition related to electricity supply, land acquisition, and visa and work permits are expected to be affected first.

The BOI has announced that FastPass eligibility requires a minimum investment of 1 billion baht in strategic sectors such as data centers, clean energy, semiconductors, electric vehicles, and digital technology.

These announcements from the BOI demonstrate policy continuity with regard to openness for foreign investments into Thailand. The government is however, increasingly shifting its focus towards increasing the competitiveness for large-scale investments in specific high-value sectors. BizWings Thailand has a team of BOI experts to navigate compliance, licensing, and BOI-related accounting specificity with clarity and simplicity. Contact us to find out more about the BOI application process, eligibility criteria, incentives, and more.

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