Let our experience be your guide.
TAX DISPUTES AND APPEALS
Historically, Thailand has not been an overly zealous litigious country. However, in recent years, as international and domestic transactions have become more complex, this has, in turn, resulted in a host of new legislation, most of it highly technical in nature. At the same time, Thailand’s Revenue Department and Large Tax Office have introduced new policies of tax audits on the “realization rule”, “classification of income”, “allocation of expenses”, and “transfer pricing”. All of which has seen a significant increase in the number of tax disputes that have arisen as corporate and financial institutions try to comply with both the new rules and the manner in which they are being interpreted.
Our experience at LawAlliance has shown us that many of these disputes are not simply about tax-related litigation, but rather involve far deeper and more complex issues which can be time consuming and which also involve a heavy commitment on the part of our clients’ internal resources.
Due to the aggressive position undertaken by the Thai Customs Department, a number of companies have been charged with customs fraud caused merely by an improper declaration of the customs base price, even without the intention to avoid any customs payments. This has usually lead to criminal charges against the authorized directors and penalties equal to four times the customs price. Something that most companies cannot afford to pay.
During the past couple years, we have stood by importers who have been unfairly accused of committing customs fraud by government officers and who have become victims of abuse by the authority. We have fought to the end and saved a number of them from such unfair treatment. LawAlliance is not a firm that is afraid of challenging government authorities and we do not provide advice simply by relying upon the current position of the Government.