Tax work covers reviewing a company's or an individual's tax position, structuring transactions before they are signed, dealing with Revenue Department enquiries and audits, and filing objections or appeals against assessments. The firm works from the underlying contracts and accounting records, because the tax treatment follows the documents rather than the intention.
Who this page is for
- Companies that received a Revenue Department enquiry or assessment
- Businesses reviewing VAT and withholding treatment before a filing
- Parties structuring a share, asset or property transaction
- Foreign individuals or companies with Thai-source income
- Groups reviewing cross-border payments and treaty positions
What the firm actually handles
- Review of corporate and personal tax positions
- VAT, withholding tax and stamp-duty treatment of specific transactions
- Tax structuring for share, asset and property transactions
- Responding to Revenue Department enquiries and audits
- Objections and appeals against assessments
- Cross-border payments and double-tax-treaty analysis
Matters clients bring us
- An assessment arrives and the deadline to object is running
- Withholding on service payments to an overseas supplier is unclear
- A share sale needs its tax consequences confirmed before signature
- A property transfer needs the fees and taxes calculated in advance
- Intercompany charges need supporting documentation
- An individual moving to Thailand needs their residence position reviewed
Documents to bring to the first meeting
- Company affidavit and financial statements for the relevant years
- Tax returns and filing receipts
- The contracts and invoices underlying the transactions in question
- Bank statements evidencing the payments
- Any assessment, enquiry letter or audit correspondence received
- Withholding certificates and VAT records
If some documents are missing, send what you have. The lawyer will tell you which office issues the remaining ones and which documents need certified translation before they can be used.
How the work proceeds
- 1Send the assessment or the transaction documents and the filings
- 2We analyse the treatment against the contracts and the records
- 3We set out the position, the exposure and the available options
- 4We prepare the response, objection or appeal within the deadline
- 5We deal with the officer or the appeal body on your behalf
- 6We advise on documentation changes so the same issue does not recur
Pitfalls and common misunderstandings
Objection deadlines are short and strict
An assessment carries a limited window to object. Losing that window narrows the options considerably, so the letter should reach a lawyer as soon as it arrives rather than after internal discussion.
The contract wording drives the tax treatment
How a payment is described in the contract and the invoice affects withholding, VAT and deductibility. Fixing the wording before signature is far cheaper than arguing about substance during an audit.
Supporting documents matter as much as the return
Deductions and treaty benefits typically depend on documentation held at the time. Reconstructing it after an enquiry begins is rarely as persuasive as records kept contemporaneously.
Handling an assessment: pay, object, or appeal
These options are sequential rather than alternative, and each has its own deadline and document set.
| Point | Pay the assessment | File an objection | Appeal further |
|---|---|---|---|
| When it applies | The assessment is correct | Within the objection window | After an objection decision you dispute |
| Documents required | Assessment and payment record | Objection, grounds and supporting evidence | Case file, the decision, and full documentary support |
| Time involved | Shortest | Moderate | Longest |
| Effect on exposure | Closes the matter for that item | May reduce or cancel the assessment | Reviewed by a further body or the court |
| Watch out for | Paying an item that was wrongly assessed | Missing the deadline or filing bare grounds | Weak documentation carried forward from the earlier stage |
The correct route depends on the assessment and the records behind it. Have both reviewed before responding.
Hand the whole matter to the firm
The firm can handle the tax file alongside the corporate and contractual work, so the documents, the filings and the response to the Revenue Department are consistent rather than prepared by separate advisers.
Tax: frequently asked questions
- I received a Revenue Department letter. What should I do first?
- Note the response deadline and identify exactly which years and items are in question. Then gather the returns, financial statements and the contracts behind those items before replying, because an early answer that is inconsistent with the documents is difficult to correct later.
- How does withholding tax work on payments to overseas suppliers?
- It depends on the nature of the payment and on whether a double-tax treaty applies, and the documentation supporting treaty relief usually needs to exist at the time of payment. Getting the contractual description right beforehand avoids most disputes.
- Is a share sale taxed differently from an asset sale?
- Yes, the consequences differ for both seller and buyer, and stamp duty, VAT and the treatment of goodwill can all vary. Because the structure is difficult to change after signature, this is analysed before the transaction documents are finalised.
- When must a business register for VAT?
- Registration is required once the statutory threshold or activity conditions are met, and some businesses register voluntarily. Late registration and incorrect invoicing are common issues that surface during an audit rather than at the time.
- How is tax residence determined for individuals?
- Presence in Thailand during a tax year is the primary factor, and residence affects which income is taxable and how foreign income is treated. Anyone relocating should have the position reviewed before the first filing rather than after.
- Can penalties and surcharges be reduced?
- There are circumstances in which they may be mitigated, and the outcome depends on the facts, the documentation and how the matter is presented. No adviser can promise a particular reduction, and we do not.
- What documentation supports intercompany charges?
- A written agreement, evidence that the service was actually provided, a basis for the charge, and invoices consistent with all of it. Charges with no supporting record are the items most often disallowed on review.
- Do you handle the accounting as well?
- We work on the legal and tax position and coordinate with your accountants, or with an accounting provider where you do not have one, so the filings and the underlying contracts are consistent.
Practice areas often handled together with this one
- Corporate & Commercial
Company formation, registry changes, contracts and foreign-investment structures
- Property & Real Estate
Title checks, sale and purchase, leases and condominium transfers
- Litigation & Dispute Resolution
Civil, criminal, labour and administrative matters through to enforcement
Speak with the lawyer responsible for Tax
เล่าเรื่องหรือส่งภาพเอกสารมาให้ทีมงานตรวจเบื้องต้น ทนายจะแจ้งแนวทาง เอกสารที่ต้องใช้ กำหนดเวลาที่ต้องระวัง และค่าบริการเป็นลายลักษณ์อักษรก่อนเริ่มงาน