Services · Practice Areas

Tax Law Services for Businesses in Thailand

Whether you are planning the tax position before a transaction, filing returns and registering for tax, facing a Revenue Department audit, dealing with a retroactive tax assessment, or preparing a case for the Central Tax Court, this page shows which matter to look at first.

Urgent matter

If you have received a notice of tax assessment from the Revenue Department, an appeal must generally be filed within 30 days of receipt. Seek advice promptly, because once the deadline has passed the position is usually difficult to remedy. Call us now →

ISpecialized services

Tax planning

Structuring the tax position correctly before a transaction takes place is usually less costly than correcting it afterward, in line with the preventive law approach. This covers both domestic business and cross-border transactions.¹

Revenue Code, Section 65, paragraph one (English translation published by the Revenue Department)¹ “Taxable income under this Part is net profit which is calculated by deducting income from business or income arising from business carried on in an accounting period with expenses in accordance with conditions prescribed in Sections 65 Bis and 65 Ter …..” The corporate income tax base therefore depends on how income is recognized and on the conditions governing non-deductible expenses, which is where advance planning makes the greatest difference.

Reviewing the business’s tax structure, setting lawful ways to reduce the tax burden, and preparing an annual tax planRevenue Code, Sections 65–76
Analyzing the tax consequences of significant transactions before they proceed, such as sales of assets, transfers of rights, and cross-border paymentsRevenue Code, Sections 40 and 65 Bis
Tax planning for business restructuring: amalgamations, business transfers, spin-offs, or the dissolution of a companyRevenue Code, Section 74
Real estate tax planning, covering income tax, specific business tax, and land and building taxLand and Building Tax Act B.E. 2562 (2019) · Revenue Code
Tax planning for families and estates, so that assets pass within the family correctly and tax-efficientlyInheritance Tax Act B.E. 2558 (2015) · Revenue Code, Section 42(10)
Preparing and reviewing transfer pricing policies in line with the standards of the Organisation for Economic Co-operation and Development (OECD)Revenue Code, Section 71 Bis · Ministerial Regulation No. 369 (B.E. 2563 (2020))

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IISpecialized services

Tax filing, registration, and certificates

We handle the filing of every type of tax return, value added tax (VAT) registration, and applications for tax certificates in Thai and English, as well as amended returns and requests to extend filing deadlines.¹

Filing corporate income tax returns, both P.N.D. 50 (annual) and P.N.D. 51 (half-year), with analysis of tax adjustmentsRevenue Code, Sections 67 Bis and 68–69
Registering as a VAT operator, notifying changes in registered particulars, and deregistering for VATRevenue Code, Section 85
Filing VAT returns and refund claims (P.P. 30), with review of recoverable input taxRevenue Code, Sections 83, 84, and 84/1
Filing monthly withholding tax returns: P.N.D. 1, P.N.D. 3, and P.N.D. 53Revenue Code, Sections 59 and 3 Tredecim
Filing additional or amended returns to correct earlier filings, including requests to reduce or waive penalties under the rules prescribed by the Director-GeneralRevenue Code, Section 27 Bis
Applying for a Certificate of Residence for tax purposes (tax residency certificate) and for extensions of filing deadlinesRevenue Code, Sections 41 and 3 Octo · Double tax agreements

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IIISpecialized services

Representation before the authorities under power of attorney

We act for taxpayers in communicating, negotiating, and submitting documents to the Revenue Department, the Customs Department, and other tax authorities, under a power of attorney properly granted in accordance with the law.

Acting before the Revenue Department on the taxpayer’s behalf under a power of attorney, including filing returns, requesting documents, and negotiating with officialsCivil and Commercial Code, Section 797 · Revenue Code
Preparing written explanations and assembling documentary evidence in response to inquiries from assessment officials, before any notice of assessment is issuedRevenue Code, Sections 19 and 23
Attending meetings and explaining the facts on behalf of the business during a tax auditRevenue Code, Sections 19 and 20
Systematically collecting, preparing, and submitting the documentary evidence requested by the Revenue DepartmentRevenue Code, Sections 19 and 87/3
Following up on tax refund claims and coordinating where refunds are delayed or refusedRevenue Code, Sections 84/1 and 27 Ter
Preparing and submitting requests for rulings to the Revenue Department (advance rulings) for transactions whose tax treatment is unclearRevenue Code · Revenue Department notifications

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IVSpecialized services

Tax appeals and tax litigation

We handle every stage of challenging and appealing a tax assessment: the audit stage, challenging the notice of assessment, appealing to the Commission of Appeal, and filing suit in the Central Tax Court.²

Revenue Code, Section 30 (English translation published by the Revenue Department)² “In appealing against tax assessment which Amphur does not have duty to assess, it shall be appealed within 30 days from the date of receiving the assessment ….. (2) subject to Section 33, it shall be appealed against the decision of the Commission of Appeal to Court within 30 days from the date of receiving the appeal decision.” These time limits are strict; once they have passed, the assessment usually can no longer be challenged.

Developing strategy and preparing written explanations at the audit stage, to prevent or reduce additional tax assessmentsRevenue Code, Sections 19–27
Preparing objections to a notice of assessment within the time limit, supported by evidence on the facts and the lawRevenue Code, Section 30 (within 30 days)
Filing appeals and conducting proceedings before the Commission of Appeal through to a final decision at that stageRevenue Code, Section 30(1)
Filing claims for refunds of tax overpaid or paid without liabilityRevenue Code, Section 27 Ter (within 3 years)
Conducting litigation in the Central Tax Court, from filing the complaint and presenting evidence through to appeals against the judgmentAct on the Establishment of and Procedure for Tax Court B.E. 2528 (1985)
Handling disputes at the tax collection stage, including summonses, seizure of assets, and orders prohibiting departure from the KingdomRevenue Code, Sections 12 and 27

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VSpecialized services

International tax

We advise on cross-border tax for foreign companies doing business in Thailand and for Thai companies with transactions abroad, covering double tax agreements (DTAs), transfer pricing, and the global minimum tax (Pillar 2).³

Analyzing benefits under the double tax agreements Thailand has concluded with more than 60 countries, and beneficial ownership issuesDouble tax agreements · Revenue Code, Section 3
Analyzing whether a foreign company’s operations in Thailand create a permanent establishment (PE)Double tax agreements, Article 5 · Base Erosion and Profit Shifting (BEPS) Action 7
Analyzing cross-border withholding tax on service fees, royalties, interest, and dividends, and claiming DTA benefitsRevenue Code, Section 70 · Double tax agreements
Advising on, preparing, and reviewing transfer pricing policies, testing whether prices are at arm’s length, and defending transfer pricing disputesRevenue Code, Section 71 Bis · Ministerial Regulation No. 369 (B.E. 2563 (2020))
Applying for an advance pricing arrangement (APA) with the Revenue Department to secure long-term certaintyRevenue Code, Section 71 Bis · Revenue Department notifications
Assessing readiness for, and the impact of, the global minimum tax (Pillar 2) for multinational groups with consolidated revenue of EUR 750 million or moreOECD Pillar 2 rules · Thailand’s top-up tax legislation

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VISpecialized services

Customs duties and international trade

We advise on customs tariff classification, rules of origin, free trade agreements (FTAs), and duty refunds under the Customs Act, for both imports and exports.⁴

Opinions on the tariff classification of imported and exported goods, and challenges to classification decisions of the Customs DepartmentCustoms Act B.E. 2560 (2017) · ministerial regulations on the customs tariff
Analyzing whether goods qualify as originating under the regional value content (RVC) or change in tariff classification (CTC) criteria, to claim reduced or zero duty under FTAsASEAN Free Trade Area (AFTA) and Regional Comprehensive Economic Partnership (RCEP)
Claiming refunds of import duty on raw materials used in manufacturing for export, including cases where a refund has been refusedCustoms Act B.E. 2560 (2017), Section 29 (drawback)
Advising on and challenging customs valuation decisions, and preparing evidence supporting the transaction valueCustoms Act B.E. 2560 (2017), Sections 16–17
Advising on benefits in free zones and bonded warehouses, including applications for approvalCustoms Act B.E. 2560 (2017)
Advising on and litigating customs disputes, including appeals against duty assessments and customs criminal casesCustoms Act B.E. 2560 (2017) · Criminal Code

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VIISpecialized services

Excise tax

We advise manufacturers, importers, and sellers of goods and services subject to excise tax, such as fuel, tobacco, liquor, motor vehicles, beverages, and entertainment venues.⁵

Analyzing whether goods or services are subject to excise tax, and the applicable rate, tax base, and legal obligationsExcise Tax Act B.E. 2560 (2017)
Opinions on, and challenges to, product classification by the Excise Department, which affects the rate and tax baseExcise Tax Act B.E. 2560 (2017), Sections 5–7
Advising on filing returns and paying tax, keeping excise accounts, and obtaining licenses from the Excise DepartmentExcise Tax Act B.E. 2560 (2017)
Challenging assessments, appealing officials’ orders, and litigating where a dispute cannot be resolvedExcise Tax Act B.E. 2560 (2017), Sections 93–101

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VIIISpecialized services

Property, family, and inheritance tax

We advise on and plan the tax aspects of transferring assets within the family, receiving inheritances and gifts, and land and building tax, matters that involve several laws at once.⁶

Structuring the transfer of assets to heirs to reduce inheritance tax lawfullyInheritance Tax Act B.E. 2558 (2015)
Advising on personal income tax on gifts of assets, including the exempt portion and the taxable portionRevenue Code, Section 42(26), (27), and (28)
Reviewing the accuracy of land and building valuations, use classifications, and tax ratesLand and Building Tax Act B.E. 2562 (2019)
Appealing land and building tax assessments and pursuing further remedies where a fair outcome is not obtainedLand and Building Tax Act B.E. 2562 (2019), Sections 73–82
Analyzing and planning the tax burden on transfers of immovable property, including income tax, specific business tax, stamp duty, and transfer feesRevenue Code, Sections 48(4) and 91/2(6)
Challenging and appealing signboard tax assessments, and advising on the correct signboard category and tax rateSignboard Tax Act B.E. 2510 (1967)

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02Frequently asked questions · FAQ

Preliminary questions that help frame a tax matter

What kinds of matters do clients usually bring to us?

Usually business tax planning, tax return filing and value added tax (VAT) registration, Revenue Department audits, retroactive tax assessments, appeals, tax cases in the Central Tax Court, transfer pricing, and international tax.

I have received a notice of tax assessment. What should I do?

Generally, an appeal against an assessment must be filed within 30 days of receiving the notice, under Section 30 of the Revenue Code. Gather the notice of assessment and the related documents and seek advice as soon as possible, because once the deadline has passed the right to challenge the assessment is usually lost.

What information should I prepare to get started?

Generally, start with the nature of the business and its transactions, the financial statements or tax returns already filed, and any documents or letters from the Revenue Department, so that the issues can be seen clearly and the statutory time limits assessed accurately.

What should a company with related-company transactions watch out for?

Transfer pricing under Section 71 Bis of the Revenue Code, and having transfer pricing documentation (TP documentation) ready before the Revenue Department calls for an audit, to show that prices between related parties follow the arm’s length principle.

What is the difference between tax planning and tax evasion?

Tax planning means structuring the business and its transactions to use, correctly, the benefits the law makes available. Tax evasion is conduct contrary to law. We work only within the first, under the preventive law approach.

What if I am not sure which service group my matter falls under?

Start by describing the business’s situation, for example that you are planning a transaction, are being audited, have been assessed, or have international transactions. We will help identify which service group to start with and which time limits must be preserved.

※Notes · Legal basis and references

↩ Revenue Code, Chapter 3 (Income Tax), in particular Section 65 on the computation of the net profit of companies and juristic partnerships, read with Sections 65 Bis and 65 Ter on the conditions for computing income and non-deductible expenses, and Sections 68–69 on the filing of returns. The Thai text of Section 65, paragraph one, as quoted above (the English text is the Revenue Department’s translation): “เงินได้ที่ต้องเสียภาษีตามความในส่วนนี้คือกำไรสุทธิ ซึ่งคำนวณได้จากรายได้จากกิจการหรือเนื่องจากกิจการที่กระทำในรอบระยะเวลาบัญชี หักด้วยรายจ่ายตามเงื่อนไขที่ระบุไว้ในมาตรา 65 ทวิ และมาตรา 65 ตรี …..”
↩ Revenue Code, Section 30, on appeals against tax assessments to the Commission of Appeal within 30 days of receiving the notice of assessment, and appeals to the court within the same period after receiving the appeal decision, read with the Act on the Establishment of and Procedure for Tax Court B.E. 2528 (1985). The Thai text of Section 30, as quoted above (the English text is the Revenue Department’s translation): “ในการอุทธรณ์การประเมินภาษีอากรที่อำเภอไม่มีหน้าที่ประเมิน ให้อุทธรณ์ภายในกำหนดเวลาสามสิบวันนับแต่วันได้รับแจ้งการประเมิน โดยให้อุทธรณ์ตามเกณฑ์และวิธีการดังต่อไปนี้ ….. (2) เว้นแต่ในกรณีห้ามอุทธรณ์ตามมาตรา 33 ให้อุทธรณ์คำวินิจฉัยอุทธรณ์ของคณะกรรมการพิจารณาอุทธรณ์ต่อศาลภายในกำหนดเวลาสามสิบวันนับแต่วันได้รับแจ้งคำวินิจฉัยอุทธรณ์”
↩ Revenue Code, Section 70, on withholding tax on payments abroad, and Section 71 Bis on transfer pricing, added by the Revenue Code Amendment Act (No. 47) B.E. 2561 (2018), read with Ministerial Regulation No. 369 (B.E. 2563 (2020)) and the double tax agreements to which Thailand is a party.
↩ Customs Act B.E. 2560 (2017), in particular Sections 16–17 on customs value, Section 29 on refunds of duty on goods imported for manufacture for export, and the provisions on bonded warehouses and free zones, read with the free trade agreements to which Thailand is a party, such as ASEAN, AFTA, and RCEP.
↩ Excise Tax Act B.E. 2560 (2017), in particular Sections 5–7 on goods and services subject to tax, and Sections 93–101 on assessment, appeals, and penalties.
↩ Inheritance Tax Act B.E. 2558 (2015), read with Revenue Code Section 42(10) on income from inheritance and Section 42(26), (27), and (28) on exempt income from gifts; the Land and Building Tax Act B.E. 2562 (2019), Sections 73–82, on objections and appeals against assessments; and the Signboard Tax Act B.E. 2510 (1967).

Tax Law Services for Businesses in Thailand

8 core practice groups

Tax planning

Tax filing, registration, and certificates

Representation before the authorities under power of attorney

Tax appeals and tax litigation

International tax

Customs duties and international trade

Excise tax

Property, family, and inheritance tax

Preliminary questions that help frame a tax matter

Articles that expand on the tax issues businesses commonly face

Not sure which service group fits your matter?