Settlement Penalties announced Under International Tax Information Exchange Law

The Ministry of Finance has issued a notification prescribing the penalty settlement criteria under Section 31 of the Emergency Decree on the Exchange of Information for Compliance with International Agreements on Taxation B.E. 2566 (2023).  

The notification dated 9 September 2026 prescribes the fines the Director-General of the Revenue Department shall impose to settle certain offences under Section 28 and 29 of the Emergency Decree, as follows: 

A penalty of THB 500,000 per offence applies where a person intentionally provides false information or conceals material facts in connection with obligations under Sections 12, 17 or 18 of the Emergency Decree. Such conduct constitutes an offence under Section 28.   

A penalty of THB 300,000 per offence applies where a reporting entity fails to comply with the reporting obligations under Section 20, constituting an offence under Section 29. 

When the Director-General has conducted the settlement, and the alleged offender has paid the fine as determined by the Director-General and within the specified timeframe, it shall be deemed that the case is terminated in accordance with the Criminal Procedure Code. 

This development forms part of Thailand's ongoing efforts to strengthen its international tax transparency framework and align with global standards promoted by the OECD, particularly those relating to the Automatic Exchange of Financial Account Information (CRS) and other tax information exchange agreements.  

The Emergency Decree, which came into force in 2023, established the legal framework enabling Thai authorities to obtain and exchange tax-related information with foreign jurisdictions pursuant to international tax treaties and agreements.  

The introduction of fixed settlement amounts provides greater certainty regarding the consequences of non-compliance and reinforces the importance of accurate reporting by financial institutions and other reporting entities subject to Thailand's international tax information exchange regime. 

Organisations with reporting obligations under the Emergency Decree should review their existing compliance procedures to ensure that information submitted to the Revenue Department is complete, accurate and supported by appropriate documentation. As tax transparency continues to be a key focus for tax authorities worldwide, robust governance and compliance controls will remain essential in mitigating regulatory risks and potential penalties. 

The Notification shall come into force from the date of its publication in the Government Gazette.