Invest1 distinct publisher3 min readPublished
The National Tax Service says one Korean manufacturer has waited since May 2023 for a fully documented withholding tax refund, and it wants Bangkok to count its investment incentives as taxes paid before the 15% floor eats them.
The Investor · Invest desk
Compiled by The InvestorSomething wrong?How this is made
The expensive part of this meeting is a subtraction problem. The global minimum tax catches groups with revenue above 750 million euros and charges additional tax equal to the shortfall whenever a subsidiary's effective rate sits below 15% [4], so a Thai entity running at 5% hands over ten points of qualifying income [2], and the Board of Investment reduction that made Thailand cheap in the first place comes back as top-up tax [10]. That is why the National Tax Service's second request costs more than its first: it wants Thailand to adopt the OECD treatment under which certain expenditure- and production-based incentives are counted as taxes paid [11], which moves the same incentive out of the column that drags your effective rate down and into the column that credits against the 15%. The source does not say which jurisdiction collects the resulting top-up, and a group modelling this has to build its forecast without knowing where that revenue lands.
Then the cash. A manufacturer prepaid withholding tax on processing fees, claimed it back with its May 2023 corporate return, submitted every document asked of it, and has not been repaid [7], which is more than thirty-six months of its working capital sitting inside the Thai treasury [1], while an exporter's zero-rated VAT refunds run months behind schedule [8]. The receivable stays on the balance sheet and earns the finance director nothing; capital financing someone else's processing queue for three years is capital not financing Thai capacity, which is the allocation cost nobody books.
The compliance line is simpler and almost as annoying: because Thailand has not joined the agreement on automatic exchange of global minimum tax information, the same return has to be filed separately in both countries [12], two preparations for one obligation [3]. Korea's own answer to that problem was to let companies key figures into Hometax instead of generating the OECD XML file [15], and it is now offering that experience across the table [16], which is generous and also self-serving, since Thailand takes its first filings next year and Korea already has one collected cycle behind it [3][14].
Thailand redesigns its incentives to the OECD standard before those first filings and the effective-rate exposure largely disappears, leaving a refund queue [11]. Or refunds speed up under pressure while the incentives stay non-qualifying, in which case every BOI holiday in a Korean group's Thai plan should be carried at a discount to face [10]. Or neither moves and the deliverable is the hotline the two sides agreed to build [13]. This is probably wrong, but I read the middle case as the likely one, because queues respond to bilateral embarrassment and hotlines, incentive design responds to revenue need, and the officials in the room were the Revenue Department's [2] while the incentives belong to the Board of Investment [10]. What would falsify it is narrow and checkable: the May 2023 claimant getting paid, and a Thai qualifying-incentive rule landing before next year's filings [7][3].
Ranked by verification strength, evidence, and original report placement.
South Korea's National Tax Service asked Thai authorities to improve tax administration after Korean companies operating in Thailand went as long as three years without receiving tax refunds and faced the prospect of shrinking tax benefits under the global minimum tax.
The National Tax Service said on the 30th that it held a working-level meeting at Thailand's Revenue Department on the 27th and conveyed the tax-related difficulties faced by Korean companies operating in the country.
The meeting was arranged so that Thailand, which will require its first global minimum tax filings next year, could draw on South Korea's experience administering the system after Korea collected its own first filings this year.
The global minimum tax applies to multinational corporate groups with revenue exceeding 750 million euros, imposing additional tax equal to the shortfall when a group's effective tax rate falls below the 15% minimum.
The National Tax Service relayed tax grievances gathered in advance through the Korean-Thai Chamber of Commerce and the Korea Trade-Investment Promotion Agency, and requested cooperation.
Delayed tax refunds were the leading complaint raised by Korean companies.
Distinct publishers with included, body-backed reporting in this cluster.
en.sedaily.com
1 article · August 29, 2026
Follow any of these and your For You feed starts watching them — no settings page required.
invest
CARF's 14 percent: Chainalysis puts $393B of taxable crypto outside the OECD's net1 distinct publisher
invest
Korea unlinks school grants from tax receipts, turning a chip windfall into a discretionary fund1 distinct publisher
product
Britain's digital infrastructure number tripled by definition, then fell 4 percent1 distinct publisher
invest
Korea names the screen: 42% of high-end corporate homes flagged as owner-family housing1 distinct publisher
Evidence-backed comparisons of source perspectives and observed adoption signals. Read the methodology
Which Builder, Operator, and Investor concerns the observed source mix emphasized—not a truth score.
Evidence, demonstrated adoption, hype gap, incentives, and confidence are assessed independently, each on its own current evidence. How these are measured.
One agency readout, no counterparty
Every specific in this story — the meeting date, the three-year wait, the complete document set, the incentive clawback risk — comes from the National Tax Service's announcement as carried by Seoul Economic Daily. The strongest facts are the institutional ones a press release can be trusted on: the €750m threshold, the 15% floor, Thailand's absence from automatic exchange. The weakest are the two anonymised taxpayers whose files no reader can inspect and whose Thai-side status nobody has asked about.
Korea's side running, Thailand's asks open
What has actually been taken up is thin but real: Korea has one filing season collected, a Hometax route that skips the OECD XML step, and a hotline both authorities agreed to. Set against that, the requests that would change a Korean group's tax bill — faster refunds, OECD credit for Board of Investment incentives, joining automatic exchange — are all still requests, and Thailand's own first filings have not happened yet.
Working-level meeting, escalation framing
A hotline and a list of asks is what a working-level meeting produced, and the reporting lets the tax agency's activity stand in for results. The 'we will make sure our companies can focus on stable business operations' pledge is doing more work than the substance behind it. The overstatement is modest rather than egregious, because the grievances themselves are concrete and dated.
Issuer telling its own story
The National Tax Service is simultaneously the source, the advocate and the subject of praise here: it collected the complaints, made the demands, and supplied the line about being first in the world to legislate the floor and about the filing system it built. A Korean business daily writing for Korean exporters has no obvious reason to test any of that, and Bangkok — which has an interest in defending its refund queue and its investment incentives — is absent.
Believable, unverified
Nothing here strains credulity — refund backlogs and Pillar Two clawback of investment incentives are ordinary problems, and the dates hold together. But a single interested source, two anonymous taxpayers and silence from the other tax authority cap how much weight the specifics can bear, so treat the three-year wait as an allegation on the record rather than an established number.