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Tax audits and dispute resolutions
LawAlliance Limited provides strategic advices, representing the clients, for a variety of the levels of tax disputes – from tax audits by relevant taxing authorities, which frequently requires an appeal to the Tax Appeal Committee, up to the court level.
With an in-depth know-how in tax laws and profound litigation experiences, combined with commercial awareness, followings are examples of recent disputes that the firm has led the clients to their triumphant results:
(1) Royalty Withholding Tax
A Thai subsidiary paying fees for offshore services rendered by its group’s regional headquarter in Singapore was assessed by the Thai Revenue Department for withholding tax on royalties, based on the rationale that provided services were related to the transfer of know-how and such fees were to be reclassified as royalties. LawAlliance Limited represented the client in making an appeal to the Tax Appeal Committee and in defending that the nature of services was that of general management and administration, the decision of which was in favour of the client.
(2) Value Added Tax (VAT) on Reinsurances
A Thai subsidiary of Japanese insurance group went into a number of reinsurance arrangements with offshore and onshore reinsurers, and was assessed by the Thai Revenue Department for the reversed-charge VAT on the reinsurance commission. The dispute was brought to the court, for which LawAlliance Limited provided strategic advices, and represented the client such that the court set a precedent case for the insurance industry by ruling in favour of the client.
(3) VAT on Multi-tier Buy-sale of Goods with Offshore Parties
A Thai subsidiary of the Japanese trade conglomerate retailed the goods produced in Thailand to the offshore customers. The transaction involved multiple tiers of cross-border transactions, and was assessed for the reversed-charge VAT by the Thai Revenue Department. LawAlliance Limited assisted the client in winning the dispute at the court.
(4) Application of Custom Duties Reduction under the Treaty
LawAlliance Limited took a part in providing strategic advices to a subsidiary of Japan automobile manufacturing company, in a court case against the Customs Department in respect of the entitlement to claim customs privileges under The ASEAN Industrial Cooperation Scheme (AICO). The client won the case.