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Tax

Tax

Key Contacts

Cambodia

Laos

Myanmar

Thailand

Jay Cohen

     +855 23 964 210

     [email protected]

Prisna Sungwanna

     +66 2056 5656

     [email protected]

Yuwadee Thean-ngarm

     +95 9 772 440 002

     [email protected]

Saravut Krailadsiri

     +66 2056 5705

     [email protected]

Kobkit Thienpreecha

     +66 2056 5534

     [email protected]

OVERVIEW

Strategic tax planning across Southeast Asia—locally informed, regionally connected.

Southeast Asia presents a diverse and rapidly evolving tax landscape, shaped by varying regulatory regimes, shifting policy priorities, and increasing scrutiny from local tax authorities. For companies operating across borders in the region, managing tax exposure and ensuring compliance requires not only technical expertise but also a nuanced understanding of local practices and regional dynamics.

With offices in Cambodia, Indonesia, Laos, Myanmar, Thailand, and Vietnam, Tilleke & Gibbins’ regional tax team is uniquely positioned to support clients across Southeast Asia. Our integrated approach combines deep local knowledge with cross-border coordination – enabling us to deliver practical, commercially focused tax solutions that align with our clients’ strategic goals.

We advise on a full spectrum of tax matters, including corporate and personal income tax, withholding tax, VAT and indirect taxes, customs duties, transfer pricing, and international tax planning. Our team works closely with clients to structure investments, optimize tax efficiency, and mitigate risks in complex transactions and regulatory environments. Whether entering new markets, restructuring operations, or navigating cross-border tax issues, we provide clear and commercially-sound advice that helps clients succeed across Southeast Asia.

Case Studies
Thailand | Technology | Tax

Tax Planning for Leading Asian Technology Company

Provided tax planning advice for a leading Asian technology company ahead of its proposed business collaboration in Thailand, including extensive advice on the structuring of the business collaboration to minimize tax exposure and liabilities.

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Thailand | Corporate/M&A, Tax

Prime Packaging’s THB 580m Sale of 100% Stake to BG Container Glass

Acted as legal counsel to the shareholders of Prime Packaging Co., Ltd. in the THB 580 million sale of a 100% stake in the company to BGC Packaging Co., Ltd., a subsidiary of BG Container Glass PCL.

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Experience

  • Advised a global leader in the heavy industries sector on various tax matters related to the supply and installation of a production platform, bridges, and a flare tower in a petroleum concession (total contract price was approximately USD 1,000,000,000).
  • Advised a group of Japanese industrial conglomerates on tax matters related to the construction of a railway project for the State Railway of Thailand. The project value is estimated to be over THB 30 billion.
  • Advising a leading hospitality property holding company in reviewing the revenue tax assessment on one of their affiliated companies with extensive land and property holdings in Thailand.
  • Acted as the exclusive Thai tax advisor to a fully integrated oil and gas corporation on various tax matters, including customs, VAT, and income tax matters and tax planning for the sale and distribution of new petroleum products in Thailand; transfer pricing issues for various sale and service transactions with its parent company; permanent establishment issues related to the sale of goods by its foreign affiliates in Thailand; and the proper structure for capital increase and loan payments to its parent/affiliate.
  • Acted as the exclusive tax advisor for a leading automaker. We advised the client on various tax matters, including tax implications and tax planning for tool sharing and various domestic and cross-border transactions with other company units, tax planning for various business operation and sales promotion plans, transfer pricing issues, and Free Zone implementation. As a result of our advice in these areas, our client was able to realize significant tax savings.
  • Advised a leading international pharmacy-led health and beauty group, which operates more than 3,200 health and beauty retail outlets around the world, on structuring corporate relationships with major department stores in Thailand, transfer pricing issues, and cross-border transactions with other company units abroad.
  • Advised a major bank in the UK, with significant retail and commercial operations in more than 50 countries around the world, on the legal and tax implications of the Long Term Cash Plan, the Private Pension Plan, and the Executive Share Award Scheme for executives who are resident in Thailand. This involved the review of hundreds of documents in relation to these executive plans. We also provide yearly updates on the legal and tax implications of these plans.
  • Acted as the Thai tax advisor to a land-based component of a leading liner shipping company on business structure, tax planning, sale of assets, and transfer pricing issues.
  • Advised one of the world’s top furniture retailers on preferential duty concessions and tax matters related to its franchise business in Thailand and sale transactions between related companies in the group.
  • Advised an international technology company on operating a representative office in Vietnam, including advising on the scope of work of a representative office, employment matters, tax matters, and government filing requirements. We prepared Vietnamese and English versions of labor contracts.
  • Advised a Singaporean company on setting up a representative office in Vietnam and handled all post-licensing matters, including providing tax and banking advice.
  • Provided guidance to multinational corporations on tax planning and structuring business projects in Thailand, transfer pricing regulations, tax implications of financing transactions, negotiating/appealing decisions of the Revenue Department, and other tax‐related issues.

PROFESSIONALS

RELATED INSIGHTS

December 12, 2025
Similar to other types of corporate disputes, tax-related conflicts often begin with an earnest attempt to resolve matters outside the courtroom. The prospect of engaging in tax litigation can be daunting, given the potential strain on commercial relationships, the legal expenses, and the uncertainty surrounding its resolution. However, there are instances when tax litigation becomes the sole avenue for seeking redress. For individuals and entities contemplating the pursuit of tax-related legal remedies, the Thai legal system offers an accessible, impartial, and equitable platform for dispute resolution. Tilleke & Gibbins’ latest update to Tax Litigation in Thailand provides an outline for navigating tax-related disputes within the Thai legal framework. It aims to equip readers with a fundamental understanding of procedures and practices within the Thai tax litigation landscape. The full guide is available through the button below.
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October 30, 2025
Thailand has introduced a comprehensive overhaul of its tax litigation procedures that will significantly impact how tax disputes are handled. The Regulations for Tax Cases B.E. 2568 (2025) take effect on November 24, 2025, and repeal the prior B.E. 2544 (2001) regulations in full. These regulations support the implementation of the Act on the Establishment of the Tax Court and Tax Case Procedure (No. 3) B.E. 2568 (2025), which expands the Tax Court’s jurisdiction to certain criminal tax matters. Published in the Government Gazette on October 14, 2025, the regulations have been reorganized into three parts covering civil cases, criminal cases, and forms, and are designed to accelerate proceedings, tighten evidentiary discipline, and modernize court operations. Structural Reform and Scope The prior regime governed only civil tax disputes. Under the new framework, the regulations introduce a dedicated chapter for criminal cases alongside updated civil procedures, as the Tax Court now has express authority to adjudicate specified criminal tax offenses. Select mechanisms applied in civil case proceedings, such as electronic communication, recording testimony, and appointing experts, also apply to criminal proceedings mutatis mutandis where they do not conflict with criminal procedure. Civil Cases: Evidence Submission, Deadlines, and Scheduling Parties must submit, together with the witness list, originals of all documentary evidence, media, or electronic data (such as files, USB drives, or CDs), and all physical evidence in the party’s possession. Failure to submit any original within the deadline (see below) results in a loss of the right to adduce that item at trial, subject only to narrow exceptions where submission is impossible due to force majeure or where receipt of the evidence is indispensable to the interests of justice. The practical impact is that parties are now obligated to assemble and verify all original documents and data at the very
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September 17, 2025
Thailand’s Ministry of Finance has introduced a five-year personal income tax exemption on capital gains from the disposal of cryptocurrency or digital tokens. The Ministerial Regulation No. 399, published in the Government Gazette on September 5, 2025, offers the personal income tax exemption for transfers occurring between January 1, 2025, and December 31, 2029. The ministerial regulation was enacted to promote Thailand as a global financial center and digital asset business hub while encouraging increased domestic investment in digital assets. Key Conditions The exemption, which covers capital gains from cryptocurrency and digital token disposals during the specified five-year period, applies only to individuals. Companies that trade in digital assets are not eligible for this tax exemption. With the tax holiday set to expire in 2029 (unless extended), individual traders should plan ahead for postexemption taxation to ensure full compliance with Thailand’s personal income tax requirements. Proper documentation of digital asset transactions during the exemption period will be essential for future tax compliance. For more details on this tax exemption, or on any aspect of Thailand’s tax law and regulations, please contact Saravut Krailadsiri at [email protected] or Papavarin Sarawongsuth at [email protected].
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July 7, 2025
On June 20, 2025, Cambodia’s Ministry of Economy and Finance issued Instruction No. 19116 to clarify when board members and company directors must receive salaries and pay payroll taxes. Board members and company directors who are not considered employees are subject to a withholding tax. This category consists of people who complete services for a nonresident individual and people who perform independent work for a company in Cambodia. Board members and company directors who are considered employees, including those appointed by a foreign head office to temporarily manage a company in Cambodia, must pay payroll taxes on any salary they receive, regardless of whether they are paid by a local or foreign branch of the company. The above obligations apply regardless of whether the person has a work permit. Board members and company directors are exempt from paying payroll tax if they: Are not present and not performing a regular management role at the company despite being registered on the company’s statutes or patent tax card; Participate only in board meetings and occasional shareholder meetings; and Do not receive a salary from a company in Cambodia. Overall, this instruction provides an important clarification regarding the tax obligations of board members and company directors. Companies should pay attention to the classification of their board members and directors and be mindful of the exemption.   This article was written with the assistance of Tilleke & Gibbins interns Amelia Gemma Erickson and Amrin Keat.
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AWARDS & RANKINGS
May 11, 2026
Tilleke & Gibbins has continued to show excellent performance in the recently released Benchmark Litigation 2026 rankings for dispute resolution firms in the Asia-Pacific region. The rankings include two jurisdictions where Tilleke & Gibbins is active: Thailand and Vietnam. Firm Rankings A full summary of the firm’s rankings is provided below: Thailand Commercial & Transactions – Tier 1 Government & Regulatory – Tier 1 Labor & Employment – Tier 1 Intellectual Property – Tier 1 Trade & Customs – Tier 2 Vietnam Commercial & Transactions (Foreign Firms) – Tier 1 Intellectual Property (Foreign Firms) – Tier 1 Labor & Employment (International Firms) – Highly Recommended (top tier awarded in this category) White Collar Crime – Recommended (top tier awarded in this category) Energy & Construction (Foreign Firms) – Tier 2 International Arbitration – Tier 2 Individual Rankings The 2026 edition also recognizes 12 Tilleke & Gibbins lawyers in Thailand—more than any other firm in the jurisdiction—and four in Vietnam. Thailand Alongkorn Tongmee – Trade & Customs Chitchai Punsan – Commercial & Transactions Chusert Supasitthumrong – Labor & Employment John Frangos – Commercial & Transactions Noppramart Thammateeradaycho – Shipping Nuttaphol Arammuang – Intellectual Property Piyawat Vitooraporn – Commercial & Transactions Pongpalin Chantrapirom – Commercial & Transactions Suebsiri Taweepon – Intellectual Property Suruswadee Jaimsuwan – Commercial & Transactions Thawat Damsa-ard – Commercial & Transactions Tiziana Sucharitkul – Commercial & Transactions, Government & Regulatory Vietnam Duc Anh Tran – Commercial & Transactions Linh Duy Mai – Intellectual Property Loc Xuan Le – Intellectual Property Tu Anh Tran – Commercial & Transactions Benchmark Litigation’s annual research is based on interviews with dispute resolution specialists and clients, as well as analysis of recent casework and market developments. To view the full results, please visit the Benchmark Litigation websites for Thailand and Vietnam.
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April 16, 2026
Tilleke & Gibbins has been recognized in the In-House Community (IHC) Firms of the Year 2025, with acknowledgments across a broad range of practice areas in Thailand and Vietnam. The results are based on feedback from in-house counsel across Asia Pacific, reflecting client perspectives on the quality and responsiveness of legal services. In Thailand, the firm received recognition in 13 categories, including 12 Firm of the Year awards and one Honorable Mention. The Firm of the Year recognitions cover: Antitrust / Competition Capital Markets Corporate & M&A Employment Energy & Projects Intellectual Property International Arbitration Litigation & Dispute Resolution Restructuring & Insolvency Taxation Technology, Media & Telecommunications Most Responsive International Law Firm – Thailand The firm also received an Honorable Mention for Real Estate & Construction. In Vietnam, Tilleke & Gibbins was recognized in seven categories. The firm received Firm of the Year awards in: Employment Intellectual Property Litigation & Dispute Resolution Technology, Media & Telecommunications Most Responsive International Law Firm – Vietnam In addition, the firm received Honorable Mentions for International Arbitration and Real Estate & Construction. The IHC Firms of the Year recognitions are based on voluntary survey responses, client feedback, testimonials, and independent research conducted by the IHC team, rather than a submission-based or benchmarking methodology. While not intended to be exhaustive, the results provide a useful snapshot of client sentiment within the in-house legal community. The full results are available on the IHC website.
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