Thailand has seen positive changes in the past few years, including being recognised as an upper-middle income country by the World Bank, and GDP growth set to hit 3.2% in 2017. The country has many ambitions, such as creating jobs to strengthen the economy, but the means to achieve these goals are not quite there yet.
Thailand has been looking at ways of expanding its tax base as a way to fund these ambitions. In the past year, the Thai government has been trying to address the challenge of taxing businesses engaged in e-commerce transactions. This includes reframing the concept of a permanent establishment. Such a business will be deemed to have a taxable presence if it has a local domain in the country and Thai currency is used in the payment or the payment leaves Thailand.
Thailand has kept its corporate tax rate at 20% to attract foreign and domestic investment in the country, in line with the World Bank's recommendations. VAT has been kept at the reduced rate of 7% and it is thought to remain at that rate for another year from October 2017.
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|Corporate Income Tax||20%|
|Net Operating Losses (years)|
|Royalties from, for example, patents, know-how||15%|
|Branch Remittance Tax||10%|
A) Certain types of interest are exempt from tax [see footnote (a) to Section F].
B) Lower rate applies to certain banks
Chairman Kitipong Urapeepatanapong oversees the tax practice at Baker McKenzie. With more than 30 years of experience, Urapeepatanapong has a wealth of knowledge in tax planning, M&A transactions, disputes and restructuring in such areas as banking, capital markets and securitisation.
The group offers the full range of tax services, including due diligence, cross-border transactions, restructuring, insolvency, litigation and disputes, as well as estate planning and wealth management. Financial services is a focus for the firm, with key strengths in banking, capital markets, derivatives, swaps and other financial products.
Baker McKenzie's team works with the Thai authorities and represents the private sector to find sound tax solutions. The firm's client base includes major domestic and international companies, financial institutions, family-owned businesses and high-net-worth individuals. These clients come from key sectors, such as finance, property development, electronics and telecommunications.
The tax and customs group at Blumenthal Richter & Sumet is headed by Sumet Mingmongkolmitr. He specialises in FDI and commercial matters in Thailand, often advising public bodies, businesses and high-net-worth individuals on such topics as capital markets and securities.
The independent firm offers a full suite of tax services, including business tax, due diligence, transfer pricing, intellectual property rights, dispute resolution, VAT and transactions. This remit extends to corporate and international tax planning in light of double tax treaties. Practice areas include trade, energy, infrastructure, land and property.
Established in 1976, the tax practice comprises a mix of Thai, European and US attorneys with legal expertise across Southeast Asia.
Anthony Visate Loh is the head of the Thai tax group at Deloitte. With more than 17 years of tax experience, Loh specialises in business model optimisation across multiple jurisdictions, including the US, China, Japan, South Korea and Malaysia, among others.
The Thai firm has more than 130 professionals, including eight partners, advising clients on all areas of tax. It is a key part of Deloitte Southeast Asia, which comprises more than 7,600 tax specialists in 25 offices across the region. The Thai practice covers the full spectrum of tax advice, such as international tax, compliance, M&A, auditing and outsourcing.
Clients are drawn from major industries like oil and gas and finance. Outside of these areas, the team has experience in consumer goods, healthcare, life sciences and technology, media and telecommunications.
Partner Jack Sheehan heads the regional tax group at DFDL, while managing director Angus Mitchell and his deputy Audray Souche lead the Thai practice. Sheehan oversees tax services across Vietnam, Cambodia, Laos, Thailand, Myanmar, Indonesia and Singapore. His expertise covers international tax, controversy, M&A, transactions, transfer pricing issues and corporate tax.
Since the practice was established in 2005, the team has focused on areas including capital markets, restructuring, insolvency and labour law. With offices in Bangkok, Samui and Phuket, DFDL offers an extensive range of tax services, including international tax, capital gains tax and transfer pricing.
The firm draws clients from major industries like energy, mining and finance, including companies listed on the Thai stock exchange.
Yupa Wichitkraisorn is the tax leader at EY Thailand. Wichitkraisorn works closely with Pathira Lamubol, who has been with the firm for more than 17 years. The Bangkok practice offers the full scope of tax services, including advice for domestic and cross-border transactions, trade, compliance, reporting and accounting. The firm's focus areas range from transactions and transfer pricing to controversy and risk management.
Benjamas Kullakattimas is the head of the tax and legal department at KPMG. She has more than 25 years of experience in the field. Her expertise covers an extensive range of tax and TP issues, such as auditing, intangibles, inter-group and advance pricing agreements.
Kullakattimas works closely with fellow partner Abhisit Pinmaneekul, who heads the transfer pricing unit and specialises in the structuring of costs, business models and supply chains. The department comprises 11 partners and 161 other professionals, divided into specialised teams focusing on international tax, corporate tax, transfer pricing and indirect tax.
KPMG Thailand takes a multinational approach and the firm collaborates with its counterparts in the Americas, Europe, Africa and the rest of Asia. The practice draws a range of clients from key sectors, including leisure, banking, infrastructure, energy and technology.
Director Thanasak Chanyapoon oversees the practice at LawAlliance with leading tax partner Piphob Veraphong. Chanyapoon and Veraphong have impressive expertise in litigation, securities, capital gains tax, investment management, as well as corporate and international tax planning. Both Veraphong and Chanyapoon previously worked at Baker McKenzie and Linklaters.
From the office in Bangkok, the tax team offers an extensive range of tax advice and support in areas such as foreign direct investment (FDI), transfer pricing, structuring, customs duties, M&A deals and other transactions. The practice's client base is drawn from key sectors, such as the finance, energy and infrastructure. Other important team members include associates Rachanee Prasongprasit and Prangtip Anantavipat.
Managing partner Till Morstadt heads the tax team at Lorenz & Partners. He works in tandem with fellow partner Naowarat Karst, who was at Deloitte before joining the firm. The team comprises three partners and 15 other tax professionals focusing on all areas of tax, including corporate tax, disputes, compliance and accounting.
Founded in 1995 by Michael Lorenz, the firm advises medium to large-sized companies, particularly European and US clients looking to invest in Southeast Asia. This remit extends to personal tax matters, inheritance, VAT and stamp duty. Lorenz & Partners maintains an international presence with headquarters in Bangkok and offices in Germany, Hong Kong and Vietnam.
Somboon Weerawutiwong is the head of tax at PwC Thailand. He works in tandem with fellow partners Ornjira Tangwongyodying and Peerapat Poshyanonda. The firm offers the complete range of tax services, including M&A deals, structuring, transfer pricing issues, risk management, dispute resolution and indirect tax. Key practice areas include financial services, such as capital markets and banking, as well as the insurance, high-tech, entertainment and energy sectors.
Counsel Sriwan Puapondh leads the tax group at Tilleke & Gibbins. She has more than 30 years of experience, including 10 years with the Thai tax authorities. Puapondh has impressive expertise in international planning for cross-border transactions, M&A deals and joint ventures.
The team comprises nine tax specialists based in Bangkok. The practice offers the full range of tax services, such as business tax, planning, transfer pricing, corporate tax, indirect tax, disputes and litigation. The firm's focus areas cover finance, manufacturing, construction and energy. Tilleke & Gibbins has a diverse client base, including major companies such as General Motors and IKEA Holdings.
The firm has a strong regional presence, with 150 lawyers and consultants in offices in Vietnam, Cambodia, Laos, Indonesia and Myanmar.