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A VAT registrant can claim a VAT refund when its input tax for a month exceeds its output tax. The excess is a tax credit under Section 82/3 of the Revenue Code, and the registrant has two options: claim a refund when filing the P.P. 30 return for that month under Section 84, or carry the credit forward to pay tax in the following month under Royal Decree (No. 242). A registrant that did not claim the refund with the return can still file a refund request within three years from the expiry of the return filing deadline for that month under Section 84/1(1). Once the refund is made, the claimant receives interest at 1% per month or part of a month, without compounding and not exceeding the amount of tax refunded, under Section 84/3 read with Section 4 decem. This article explains both routes step by step, the time limits, input tax that cannot be used for a refund, Supreme Court case law, and the European Union law used for comparison.

Status of the law as at 15 October 2026: The provisions quoted in this article are taken from the Revenue Department website, checked on 15 October 2026, namely Sections 80/1, 82/3 and 82/5 (web page last updated 30 October 2023), Sections 83, 83/4 and 84 to 84/3 (last updated 18 March 2024), Section 4 decem (last updated 8 July 2026), Royal Decree (No. 242) B.E. 2534 (1991) and Revenue Department Order No. Tor.Por. 113/2545.1 As for Ministerial Regulation No. 161 (B.E. 2526 (1983)), which prescribes the rules for paying interest under Section 4 decem, the author could not open its link on the Revenue Department website on the date of checking, so this article does not state the date from which interest starts to run.2 This page is an English translation of the Thai original; the Thai text prevails.

Key points

Contents
  1. When Can You Claim a VAT Refund? When Input Tax Exceeds Output Tax under Section 82/3
  2. Claiming a Refund with the P.P. 30 Return or Carrying the Credit Forward to Next Month: Which to Choose
  3. Filing a Refund Request within Three Years under Section 84/1
  4. Filing an Additional Return under Section 83/4 to Claim a Refund
  5. Input Tax That Cannot Be Used for a Refund under Section 82/5
  6. Interest on VAT Refunds under Section 84/3 and Section 4 decem
  7. VAT Refunds on Imports under Section 84/2
  8. Documents to prepare before claiming a VAT refund
  9. Supreme Court case law on VAT refunds
  10. Comparative law: the European Union and reasonable refund periods
  11. Law and economics, and interdisciplinary insights: why slow tax refunds are a cost to business
  12. The VAT refund process: a step-by-step summary
  13. Frequently asked questions about VAT refunds

When Can You Claim a VAT Refund? When Input Tax Exceeds Output Tax under Section 82/3

Thai VAT is calculated monthly. Paragraph one of Section 82/3 provides: “If input tax exceeds output tax, the difference shall be tax credit and business person shall be entitled to tax refund or tax payment in accordance with Part 8” (official translation by the Revenue Department).3 The right to a refund is therefore the result of the calculation, not a special privilege that requires approval in advance. Operators whose input tax regularly exceeds their output tax usually fall into three groups: exporters, whose output tax is charged at 0% under Section 80/1(1) but who still pay input tax on their costs at the normal rate; providers of services that are used abroad, under Section 80/1(2); and businesses that have just invested in machinery, buildings or large amounts of inventory before they start earning revenue.4

Paragraph two of Section 82/3 also allows input tax that was not deducted in the month in which the tax invoice was received, because of a necessary cause prescribed by the Director-General, to be deducted in a later month, “but not exceeding 3 years as from the date of issuance of tax invoice” (official translation by the Revenue Department).3 This matters for refunds: a tax invoice that arrives late or is overlooked can no longer be used to create a tax credit once three years have passed from the date it was issued, whichever refund method is used.

Claiming a Refund with the P.P. 30 Return or Carrying the Credit Forward to Next Month: Which to Choose

Section 84 allows a remaining tax credit to be used in two ways: the VAT registrant is entitled to “carry it for the value added tax payment in accordance with rule, procedure and condition prescribed by the Royal Decree or to claim for refund at the time of filing of tax return of such tax month under Sections 83 or 83/1” (official translation by the Revenue Department).1 A return under Section 83 must be filed by the fifteenth day of the following month, unless the Director-General prescribes otherwise, and must be filed every month even if there are no sales.5

Section 3 of Royal Decree (No. 242) B.E. 2534 (1991) sets out how the credit is carried forward: the operator is entitled to apply the remaining tax credit “towards value added tax in the tax month following the tax month in which that tax was calculated” and, if credit still remains, “shall be entitled to apply it towards value added tax in the next tax month” (unofficial translation). Paragraph two requires those who do not exercise the right to carry the credit forward to “file a request for value added tax refund in the form prescribed by the Director-General” (official translation by the Revenue Department).6

Comparing the two routes for a tax credit under Section 84
IssueCash refundCarrying the credit forward to the next month
Legal basisSection 84 (refund claimed with the return) or Section 84/1 (request filed later)Section 84 read with Section 3 of Royal Decree (No. 242)
Suited toExporters, or businesses whose input tax has exceeded output tax for several consecutive months, so that there will not be enough output tax to offset it in the near futureBusinesses whose input tax exceeds output tax only occasionally and that expect to have output tax in the following month
Effect on liquidityCash comes back, together with interest under Section 84/3 once the refund is madeReduces the tax payable in the following month; no interest
Tax auditRevenue officials examine the tax invoices and transactions before the money is refundedNo refund approval step, but the credit can still be audited later within the limitation period for assessment

Once the carry-forward route has been chosen, changing course later to claim a refund calls for care to avoid double counting. Supreme Court Judgment No. 3412/2541 held that a remaining tax credit must be applied towards tax in the following tax months in sequence, and cannot skip ahead to be used in a more distant month.7 In practice, the same credit can be used only one way: once it has been deducted in the following month’s return, it cannot also be claimed as a refund. Operators should therefore keep a monthly tax credit control schedule showing whether each month’s credit has been carried forward, refunded or is still outstanding.

Filing a Refund Request within Three Years under Section 84/1

Those who did not claim a refund with the return still retain the right. Section 84/1(1) provides that, where “there is tax to be refunded but a VAT registrant does not claim a refund under Section 84, the VAT registrant shall be entitled to file a request for tax refund within 3 years as from the day after the last day on which the tax return is required to be filed in that tax month” (official translation by the Revenue Department). Item (2) applies to other cases, such as tax overpaid because of a calculation error, where the request must be filed “within 3 year[s] as from the date of tax payment” (official translation by the Revenue Department).8

In Supreme Court Judgment No. 11260/2558, the Supreme Court affirmed this principle: “where a VAT registrant has not claimed a VAT refund under Section 84, it is entitled to file a request for a tax refund within a period of 3 years from the expiry of the deadline for filing the tax return in which the refund is claimed” (unofficial translation).9 For example, for a tax credit for January 2024 (B.E. 2567), whose return filing deadline ended on 15 February 2024 (disregarding the extension for filing online), the refund request must be filed within three years from the expiry of that deadline. Those who file returns online should check which date is the deadline used for the calculation, and should not wait until the time limit is about to run out.

The request must be in the form prescribed by the Director-General. The Supreme Court refers to this request as Form Kor.10 and, in Supreme Court Judgment No. 7383/2547, held that a VAT refund request on Form Kor.10 does not require an appeal before the case is taken to court.10 As to where to file, paragraph three of Section 84/1 requires the request to be filed in the locality in which the place of business is located, separately for each place of business, unless approval has been granted to file returns and pay tax jointly.8 Article 1 of Revenue Department Order No. Tor.Por. 113/2545 designates “the Area Revenue Office or the Area Revenue Branch Office as the place for filing requests for tax refunds” (unofficial translation) for those entitled to a refund within that locality.11

Filing an Additional Return under Section 83/4 to Claim a Refund

Where a return already filed is incorrect or incomplete, Section 83/4 provides that the operator shall “file an additional tax return together with tax payment, if any, correctly at the place of the prior filing of tax return” (official translation by the Revenue Department).12 The final part of Section 84 confirms that, if the additional filing results in a tax credit, the operator “shall be entitled to claim for refund at the time of filing of such additional tax return” (official translation by the Revenue Department).1

In Supreme Court Judgment No. 444/2549, the Supreme Court held that filing an additional return under Section 83/4 gives a right only to claim a refund, not to carry the amount forward as a tax credit to the following month.13 In Supreme Court Judgment No. 3587/2550, the Court said of filing an additional return to claim a refund that “the law does not prescribe a time frame for filing this additional VAT return” (unofficial translation),14 but it held that an additional return filed within three years from the expiry of the return filing deadline for that tax month under Section 84/1(1) was filed within the time prescribed by law, so the operator was entitled to interest on the refund. These two cases mean that an operator who discovers overlooked input tax must choose the right route: to carry it forward as a credit, the operator must exercise the right under paragraph two of Section 82/3 within three years from the date the tax invoice was issued; to obtain a cash refund by correcting the original return, it should file an additional return together with a refund claim. Readers should read the full judgments before applying them to their own facts, because the outcome of each case depends on the sequence in which the returns and requests were filed.

Input Tax That Cannot Be Used for a Refund under Section 82/5

The most common reason a refund claim is cut back is non-deductible input tax. Section 82/5 prohibits six categories of input tax from being deducted in the calculation under Section 82/3, and where input tax cannot be deducted, no tax credit arises to be refunded.15

Non-deductible input tax under Section 82/5 and what to check before claiming a refund
ItemNon-deductible input taxWhat to check
(1)No tax invoice, or the tax invoice cannot be produced, unless there is a reasonable cause as prescribed by the Director-GeneralOriginal tax invoices or electronic tax invoices for every entry in the input tax report
(2)The tax invoice contains incorrect or incomplete particulars in an essential respectThe buyer’s name, address, taxpayer identification number and branch match the registration
(3)Input tax not directly related to the carrying on of the businessPersonal expenses of directors, or expenses of other businesses in the group
(4)Input tax on entertainment expenses or similar expensesEntertainment meals and gifts recorded together with selling expenses
(5)Tax invoice issued by a person not entitled to issue tax invoicesThe seller’s VAT registration status on the date the tax invoice was issued
(6)Input tax as prescribed by the Director-General with the approval of the Minister (Director-General’s Notification No. 42 and subsequent notifications)Check the items in the Director-General’s notifications referred to in Section 82/5(6) before deducting input tax

A business that carries on both taxable and non-taxable activities must first allocate its input tax under Section 82/6; input tax allocated to the non-taxable activities does not create a tax credit.15 Those who claim refunds without making this allocation therefore often have the amount reduced when revenue officials examine the claim.

Interest on VAT Refunds under Section 84/3 and Section 4 decem

Section 84/3 provides: “Upon being refunded value added tax, a person receiving tax refund shall be entitled to interest under the conditions in Section 4 Decem” (official translation by the Revenue Department).16 Section 4 decem provides that the Director-General shall “order interest to be paid to a person receiving a tax refund at the rate of 1% per month or part of a month on the amount of tax refunded, without compounding” (unofficial translation), in accordance with the rules in the Ministerial Regulation, and paragraph two sets a cap: “Interest paid under paragraph 1 shall not exceed the amount of tax refundable” (official translation by the Revenue Department).2

A rate of 1% per month without compounding is equivalent to roughly 12% a year, which is higher than ordinary deposit interest rates. A refund delayed because revenue officials take a long time to examine it therefore does not mean the operator loses out entirely. However, the date from which interest starts to run depends on Ministerial Regulation No. 161 (B.E. 2526 (1983)), whose original text the author has not yet checked. Claimants should ask the revenue official to show the interest calculation in the refund notice, and compare it with the Ministerial Regulation before accepting the money.

VAT Refunds on Imports under Section 84/2

VAT paid on importation is input tax of a VAT registrant and is refunded through the normal monthly calculation. Section 84/2, however, contains two specific cases: (1) an importer with an objection under the customs law, or whose case is before a court, must claim the refund “within six months from the date of receiving written notice of the decision on the import duty objection, or from the date of the final judgment” (unofficial translation); and (2) an importer that is not registered and sends the goods back abroad claims the refund under the same rules as an import duty refund, filing at the customs station of import.17 This six-month period is much shorter than the three years under Section 84/1, so importers in a dispute over customs value should record the date on which they receive notice of the decision immediately.

Documents to prepare before claiming a VAT refund

The Revenue Code does not list the documents required for a refund claim in Section 84 or 84/1, but officials have the power to verify the accuracy of input tax and output tax before making a refund. The following list is therefore the set of documents the author recommends preparing, based on experience; it is not a list prescribed by law.

  1. Form P.P. 30 for the month in which the refund is claimed, and for each preceding month from which a credit was carried forward, together with a monthly tax credit control schedule
  2. The input tax report, the output tax report, and the goods and raw materials report for that month
  3. The originals of the purchase tax invoices, or verifiable electronic tax invoice files
  4. Evidence of payment to the sellers, such as bank statements, to show that the transactions actually took place
  5. For exporters: export declarations, commercial invoices, and evidence of payments received from abroad, which link sales taxed at 0% under Section 80/1 to the output tax report
  6. Contracts or purchase orders for high-value input tax items, and evidence that those items relate directly to the business, for the purposes of Section 82/5(3)

Supreme Court case law on VAT refunds

The Supreme Court has ruled on VAT refunds in five cases covering four issues that arise frequently: the three-year time limit, additional tax returns, carrying credits forward, and the steps to take before filing a lawsuit. This table summarizes the effect of each case on refund claims.

Supreme Court judgments checked by the author in the Supreme Court’s judgment search system
JudgmentIssueEffect on refund claims
11260/2558The three-year time limit under Section 84/1(1)Runs from the day after the filing deadline for the month in which the refund is claimed
3587/2550Filing an additional tax return to claim a refund and interestThe law sets no time frame for filing an additional tax return, but a return filed within the three years under Section 84/1(1) is treated as filed in time, and interest is awarded
444/2549Additional tax return under Section 83/4Confers only a right to claim a refund; the excess cannot be carried forward as a credit to the following month
3412/2541Carrying a tax credit forward to the following month, citing Sections 84 and 89/1The credit must be carried forward to the following month in sequence; it cannot skip ahead to be used in a more distant month
7383/2547Refund request on Form Kor.10No appeal is required before filing a lawsuit

Comparative law: the European Union and reasonable refund periods

Article 183 of Council Directive 2006/112/EC (the European Union’s directive on the common system of value added tax) lays down the same principle as Section 84 in Thailand: where input tax exceeds output tax, Member States "may ... either make a refund or carry the excess forward" (that is, refund the money or carry the balance forward to the following period), in accordance with conditions which each Member State determines.18 The difference is that the Court of Justice of the European Union (CJEU) applies the principles of fiscal neutrality and proportionality to check that those conditions do not leave business operators bearing the tax for an unreasonably long time.

In Sosnowska (C-25/07, 10 July 2008), the Court held that Polish legislation extending the refund period for one group of business operators "from 60 to 180 days" unless they lodged security of PLN 250,000 was contrary to the Directive.19 In Enel Maritsa Iztok 3 (C-107/10, 12 May 2011), the Court held that Bulgaria’s normal refund period of 45 days was not contrary to Article 183, but that postponing the date from which interest runs until a tax audit has been completed was contrary to the principle of fiscal neutrality, and that a refund may be made by setting it off against other tax debts.20 By comparison, in Thailand Sections 84/3 and 4 decem already provide for interest once a refund is received, but the Revenue Code sets no number of days within which the Revenue Department must complete the refund. Thai business operators therefore have no statutory right to require a refund within any particular number of days; interest is their only compensation.

Law and economics, and interdisciplinary insights: why slow tax refunds are a cost to business

In economic terms, VAT is designed so that the burden falls on the final consumer, while business operators along the chain merely collect and remit it. Input tax awaiting refund is therefore equivalent to working capital that a business has lent to the state. The cost of waiting for a refund is the opportunity cost of that money, which is highest for export businesses with low profit margins that rely on revolving short-term loans. Interest under Section 4 decem serves two purposes: it compensates business operators for their opportunity cost, and it gives the collecting authority an incentive not to delay refunds unnecessarily, because late refunds have a cost to the state itself.

On the other hand, the refund system is a major channel for fraud. The work of Keen and Smith (2006) describes various forms of VAT fraud, including fabricating tax invoices to claim refunds from the state,21 and the report by Harrison and Krelove for the International Monetary Fund (2005) reviews the VAT refund experience of many countries, which must strike a balance between refunding quickly and screening high-risk claims.22 This perspective explains why officials examine refund claims more strictly than ordinary tax payments, and why business operators whose documents are complete, whose transactions can be traced back, and whose input tax is consistent with their sales clear the examination faster. Investing in a documentation system is therefore a way to reduce the cost of waiting for a refund, not an additional burden.

The VAT refund process: a step-by-step summary

A VAT refund claim begins with closing the monthly tax reports correctly and then choosing a route according to the status of the tax credit. The following sequence is compiled from the statutory provisions and the case law discussed above.

  1. Close the input tax and output tax reports for the month, remove non-deductible input tax under Section 82/5, and allocate input tax under Section 82/6 if the business carries on both taxable and non-taxable activities.
  2. If input tax exceeds output tax, decide whether to claim a cash refund or carry the credit forward, taking into account the projected output tax for the following month.
  3. If claiming a refund, indicate the intention to claim a refund on Form P.P. 30 filed within the deadline under Section 83.
  4. If that deadline has passed, file a refund request on the form prescribed by the Director-General (Form Kor.10) at the Area Revenue Office within three years under Section 84/1.
  5. If the original return was incorrect, file an additional tax return under Section 83/4 and claim the refund together with that return.
  6. When the officials schedule an examination, submit the documents in the list above, and ask that the letter notifying the result state how the refund amount and the interest were calculated.
  7. If the claim is rejected or no result is received within a reasonable time, seek advice on filing a lawsuit in the Tax Court; under Supreme Court Judgment No. 7383/2547, a refund request on Form Kor.10 does not have to go through an appeal first.

Readers who want an overview of the VAT system before reading about refunds should read VAT registration (Thai). For items that are exempt and give rise to no input tax to deduct, read Goods and services exempt from VAT under Section 81 (Thai). For VAT refunds for tourists, which are a separate system, read How to apply for approval as a VAT Refund for Tourists shop (Thai). If a refund claim leads to a tax assessment, read Appealing against a tax assessment.

Frequently asked questions about VAT refunds

Short answers to the questions business operators ask most often about VAT refunds. Each answer cites the statutory provision or judgment explained in the preceding sections.

When can you claim a VAT refund?
When input tax for a tax month exceeds output tax, the difference is a tax credit under Section 82/3. A VAT registrant may choose to claim a refund with Form P.P. 30 under Section 84, or to carry the credit forward to pay tax in the following month under Royal Decree (No. 242).
If you did not claim a refund when filing Form P.P. 30, how long do you still have to claim it?
You may file a refund request within three years from the day after the deadline for filing the return for that tax month, under Section 84/1(1), as the Supreme Court confirmed in Judgment No. 11260/2558.
Where do you file a VAT refund request?
At the Area Revenue Office or Area Revenue Branch Office in the locality where the place of business is located, under Section 84/1, paragraph three, and Revenue Department Order No. Tor.Por. 113/2545. A business with several places of business must file separately for each one, unless approval has been granted to file jointly.
Do you receive interest on a VAT refund?
Yes. Section 84/3, read with Section 4 decem, provides for interest at 1% per month or part of a month, not compounded, and not exceeding in total the amount of tax refunded, in accordance with the rules in the Ministerial Regulation.
What input tax cannot be used to claim a refund?
Non-deductible input tax under Section 82/5, for example where there is no tax invoice, where the tax invoice is incorrect in its essential particulars, input tax not directly related to the business, entertainment expenses, and tax invoices issued by persons not entitled to issue them.
If an additional tax return produces a tax credit, can it be carried forward to the next month?
Section 84 allows a refund to be claimed together with the additional tax return, and in Supreme Court Judgment No. 444/2549 the Court held that filing an additional tax return under Section 83/4 confers only a right to claim a refund; it does not allow the credit to be carried forward to the following month.
If a refund request is rejected, must you appeal before going to court?
In Supreme Court Judgment No. 7383/2547, the Court held that a VAT refund request on Form Kor.10 does not require an appeal before a lawsuit is filed. A tax assessment issued at the same time, however, has its own appeal procedure, so you should check what type of order the letter you received is.