Key Takeaways
- The Cabinet approved a new Liability for Defective Goods Act, a Thai "lemon law" that would apply to both business-to-consumer and business-to-business sales and impose defined repair, replacement, price-reduction, and rescission remedies on sellers. It is an approved bill heading to Parliament, not yet law, and it is drafted to reach contracts signed before it takes effect.
- Two lapsed electronic-tax incentives are set to return: a 200 percent (double) corporate deduction for investing in and using the e-Tax Invoice & e-Receipt and e-Withholding Tax systems, and a reduced 1 percent withholding rate for payments made through e-Withholding Tax. Both were approved in principle for 1 January B.E. 2569 (2026) to 31 December B.E. 2570 (2027), but the implementing instruments are not yet published.
- Thailand will join the OECD's GloBE Multilateral Competent Authority Agreement, the channel for exchanging Pillar Two top-up-tax information on large multinational groups. Thailand's domestic top-up tax is already in force; the first information exchange with treaty partners is targeted for December B.E. 2570 (2027).
- The double tax deduction for donations to education and sport made through the Revenue Department's e-Donation system is set to be extended for three years, from 1 January B.E. 2568 (2025) to 31 December B.E. 2570 (2027), but again awaits publication.
- The mandatory food-contact paper standard that was due to bite on 22 June B.E. 2569 (2026) is set to be pushed back one year to 22 June B.E. 2570 (2027). The deferral was only approved in principle, so makers, importers, and sellers should not assume relief until the amending regulation is published.
1. Thailand's "lemon law" cleared the Cabinet and is headed to Parliament.
The Cabinet approved the draft Liability for Defective Goods Act B.E. .... (the Product Defect Liability Act), as reviewed by the Council of State's special drafting committee (Completed Matter No. 615/2567) and proposed by the Office of the Consumer Protection Board (OCPB). The bill will go to the House of Representatives as the principal draft, alongside a citizen-initiated bill submitted by Ms Saree Aongsomwang and 21,111 eligible voters under Section 147 of the Constitution. The aim is to give buyers clearer protection than the general defect provisions of the Civil and Commercial Code, particularly for hidden defects that a buyer cannot see at delivery.
The reach is broad. The Act would bind any seller who sells goods in the ordinary course of business, and would apply to both business-to-consumer and business-to-business sales, as well as to hire-purchase, third-party-financed sales, and barter. It is drafted to apply to contracts made before it takes effect, and it excludes used goods and live animals. Where a defect appears within a set window, the law presumes the defect existed at delivery: six months for general goods, one year for cars, and six months for motorcycles. The remedies are specific. For cars, the seller is liable for defects appearing within one year or 10,000 kilometres; for motorcycles, six months or 5,000 kilometres; a material safety-related defect can require replacement or rescission, and a non-material defect must first be repaired, with price reduction or rescission if a car is not fixed within 90 days or a motorcycle within 60 days. Electrical, electronic, and engine-driven appliances carry a 14-day replacement right for material defects. The limitation period runs one year for general goods and two years for vehicles and appliances.
This is a Cabinet-approved bill, not yet enacted law, and the substance can still change as Parliament debates it against the competing citizen bill. The direction, however, is set, and the compliance lift for sellers will be real: warranty terms, returns and repair workflows, dealer and distributor contracts, and after-sales documentation will all need to be re-papered. Action: by 31 July B.E. 2569 (2026), manufacturers, importers, and retailers (especially in automotive and electronics) should have counsel map the bill against current warranty, returns, and dealer-agreement terms so a redraft is ready before enactment.
2. The electronic-tax incentives are coming back, but are not yet in force.
The Cabinet approved in principle two Finance Ministry instruments that revive tax incentives for electronic tax systems that lapsed on 31 December B.E. 2568 (2025). A draft Royal Decree under the Revenue Code restores the 200 percent (double) corporate income tax deduction for investing in, and paying to use, the e-Tax Invoice & e-Receipt and e-Withholding Tax systems, and newly extends that deduction to the information-system audit fees that service providers pay to the Electronic Transactions Development Agency (ETDA). A separate draft Ministerial Regulation restores the reduced withholding tax rate of 1 percent, down from the usual 5, 3, and 2 percent, for assessable income paid to juristic persons (excluding foundations and associations) and individuals through e-Withholding Tax. Both are intended to run from 1 January B.E. 2569 (2026) to 31 December B.E. 2570 (2027). The prior measures were granted by Royal Decree No. 766 B.E. 2566 (2023) and Ministerial Regulation No. 389 B.E. 2566 (2023).
Two points matter for planning. First, neither instrument is law yet: the Royal Decree and Ministerial Regulation still need to be finalised and published in the Royal Gazette, even though the intended coverage is backdated to 1 January B.E. 2569 (2026). To bridge the gap on the withholding side, the Finance Ministry already issued an announcement dated 6 February B.E. 2569 (2026) allowing remitters who used e-Withholding Tax for payments made between 1 January and 31 March B.E. 2569 (2026) to top up any shortfall by 30 April B.E. 2569 (2026). Second, the cash-flow value is significant: the Finance Ministry estimates the e-Withholding Tax measure does not reduce net tax revenue but frees up roughly THB 27 billion in business cash flow each year, while the investment deduction is expected to cost about THB 33 million a year, or about THB 66 million over the two tax years, in forgone corporate tax. Action: finance teams should keep applying the 1 percent e-Withholding Tax rate per the bridging announcement, but treat the double deduction as confirmed only once the Royal Decree and Ministerial Regulation appear in the Royal Gazette; ask your tax adviser to flag publication.
3. Thailand is joining the OECD's Pillar Two information-exchange agreement.
The Cabinet approved Thailand acceding to the Multilateral Competent Authority Agreement on the Exchange of GloBE Information (the GloBE MCAA), the OECD-standard mechanism through which jurisdictions exchange the top-up-tax information of large multinational enterprise groups under the global minimum tax. Thailand has already enacted the Emergency Decree on Top-up Tax B.E. 2567 (2024), published in the Royal Gazette on 26 December B.E. 2567 (2024), which applies the OECD's 15 percent global minimum effective rate to in-scope groups (those with annual consolidated revenue of at least EUR 750 million) and requires top-up tax to be computed from 2568 (2025). Joining the GloBE MCAA is the step that lets Thailand share and receive the GloBE Information Return (GIR) with treaty partners.
For in-house tax and finance teams at multinational groups operating in Thailand, this confirms that Thailand is wiring itself into the international Pillar Two reporting network rather than standing apart from it. The domestic top-up tax obligation is the part already in force and is what drives current compliance; the GloBE MCAA governs how the resulting data moves between tax authorities. On the current timetable, the first GIR is due to be filed with the Revenue Department by June B.E. 2570 (2027), and the first cross-border exchange with treaty partners is targeted for December B.E. 2570 (2027). The practical implication is that GIR data filed in Thailand should be prepared on the assumption it will be shared internationally. Action: before year-end B.E. 2569 (2026), multinational groups in scope of the global minimum tax should confirm their Thai entity's top-up-tax registration and GIR data readiness with their group tax function, ahead of the June B.E. 2570 (2027) filing and December B.E. 2570 (2027) exchange.
4. The double deduction for e-Donation to schools and sport is being extended.
The Cabinet approved in principle two draft Royal Decrees under the Revenue Code that extend, for three more years, the tax benefit for individuals and companies donating money or property to educational institutions and to support sport through the Revenue Department's e-Donation system. Donors can deduct twice the donated amount, subject to the usual cap of 10 percent of net assessable income (for individuals) or net profit (for companies) when combined with other double-deduction donations. The previous measure lapsed on 31 December B.E. 2567 (2024); the extension is intended to run, retroactively, from 1 January B.E. 2568 (2025) to 31 December B.E. 2570 (2027). The Finance Ministry estimates about one million taxpayers use the benefit each year, at a cost of roughly THB 1,600 million a year in forgone revenue, split between education at about THB 1,540 million and sport at about THB 60 million.
As with the electronic-tax measures, these are draft Royal Decrees approved in principle, not yet published, and the Revenue Department will issue a Director-General's notification setting the detailed criteria once they take effect. The benefit is worth building into corporate social responsibility and tax planning, but only donations routed through the e-Donation system qualify, and only to eligible recipients (state and private educational institutions, and designated sports bodies such as the Sports Authority of Thailand and registered provincial and national sports associations). Action: companies planning education or sport donations this year should route them through the Revenue Department's e-Donation system and retain the e-Donation records, then confirm the deduction once the Royal Decrees are published.
5. The food-contact paper standard that was about to bite is being pushed back a year, but only in principle.
The Cabinet approved in principle a draft Ministerial Regulation deferring, by one year, the date on which food-contact paper products must comply with the mandatory industrial standard TIS 2948-2562 (มอก. 2948-2562). The original Ministerial Regulation B.E. 2568 (2025) was published in the Royal Gazette on 24 December B.E. 2568 (2025) and was due to take effect 180 days later, on 22 June B.E. 2569 (2026). The amendment moves that compliance date to 22 June B.E. 2570 (2027). Once it does bite, makers and importers of food-contact paper products must hold a licence under Section 20 or 21 of the Industrial Product Standards Act B.E. 2511 (1968) (as amended), and sellers may only sell licensed product bearing the standard mark; breaches carry imprisonment of up to two years, a fine of up to THB 2 million, or both, under Section 48.
The deferral followed industry feedback that printing and packaging SMEs are not ready, including difficulties sourcing certified recycled pulp and upgrading machinery and quality controls. The crucial point for affected businesses is timing and status: the original 22 June B.E. 2569 (2026) compliance date is days away, and the one-year deferral has only been approved in principle. It is not yet in force and must itself be published in the Royal Gazette before that date to take effect. Until it appears, the prudent assumption is that the standard still applies on 22 June B.E. 2569 (2026). Action: makers, importers, and sellers of paper food packaging should confirm the deferral's Gazette publication before 22 June B.E. 2569 (2026) rather than assume it, and use any extra year to obtain TIS 2948-2562 licensing.
Also worth noting
- ASEAN-Russia summit documents (foreign policy, non-binding): the Cabinet approved four draft outcome documents for the special ASEAN-Russia Summit, to be endorsed in Kazan on 18 June B.E. 2569 (2026): the Kazan Declaration 2026, joint statements on energy and on cultural cooperation, and a Comprehensive Plan of Action 2026 to 2030. The government confirmed these create no international legal obligation and are not treaties under Section 178 of the Constitution. They signal deeper ASEAN-Russia economic engagement, but any actual dealing with Russian counterparties remains subject to applicable international sanctions and export-control regimes; obtain a sanctions screen before committing.
- Listed companies, a hard deadline is two weeks away: separately from this Cabinet session, the Capital Market Supervisory Board's new notification on material transactions (No. TorJor. 45/2568), with parallel changes to the connected-transaction rules, takes effect on 1 July B.E. 2569 (2026). It introduces a minority-shareholder veto mechanism and reinforces substance-over-form for asset acquisitions and disposals. Listed-company clients should review their material-transaction and connected-transaction approval matrices before 1 July.
- Travellers and HR teams: the visa-exemption overhaul that the Cabinet approved on 19 May B.E. 2569 (2026), cutting the 60-day visa-free stay to 30 days for most eligible countries, remains pending publication in the Royal Gazette and is not yet effective. Watch for the Gazette before advising on entry plans.
- Machinery-of-government and energy items: the Cabinet also cleared a restructuring of the Office of the Council of State, two university faculty reorganisations, several production-sharing and joint-production documents for the Thailand-Malaysia Joint Development Area, an MOU with Vietnam's Ministry of Industry and Trade, and a senior civil-service reshuffle. These are administrative, sector-specific, or personnel items with no general client impact.
Where we can help
For sellers, manufacturers, and importers preparing for the Product Defect Liability Act, our Corporate & Commercial team advises on warranty, returns, and dealer-agreement redrafting, and our Litigation & Dispute Resolution team on the new remedy and limitation regime. For food-packaging makers and importers, our Corporate and Regulatory lawyers advise on TIS licensing and the compliance timeline. Our Taxation team advises on the electronic-tax incentives, the e-Donation deduction, and global-minimum-tax (Pillar Two) registration and GIR readiness. To arrange a 30-minute strategy call, contact [email protected].
Disclaimer: This publication is intended for general informational purposes only and does not constitute legal advice. The information contained herein should not be relied upon as a substitute for specific legal counsel. For advice tailored to your circumstances, please contact Dej-Udom & Associates directly.