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Tax

Tax

Key Contacts

Cambodia

Laos

Myanmar

Thailand

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.

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

June 3, 2025
On March 12, 2025, Cambodia’s Ministry of Economy and Finance issued Prakas No. 192 on Tax Rules and Procedures for Trust to determine the tax rules and procedures for trust operations. With the exception of trusts whose legal form is a company or enterprise, all trustors, trustees, and beneficiaries engaged in trust operations in Cambodia are subject to this new regulation. Taxpayer Registration A trustee company must register as a medium or large taxpayer. An independent individual trustee must register as a small, medium, or large taxpayer depending on the amount of turnover or the value of the fixed assets of the business, as stipulated in the Prakas on the Clarification of Taxpayers under the Self-Assessment Regime. Independent individual trustees must register as taxpayers within 15 working days from the commencement of economic activity or from the receipt of a license or authorization from the Trust Regulator. Accounting Records Accounting records should follow the rules stipulated in Article 6 of the Law on Taxation., which requires small taxpayers to use simplified accounting, while medium and large taxpayers must adhere to the Cambodian International Financial Reporting Standards (CIFRS).The trustee must maintain separate accounting records between its own operations and the trust. If the trustee manages more than one trust, the trustee must prepare separate records for each trust. For all the records, the trustee must clearly identify the ownership of all assets, liabilities, expenses, and other transactions. Taxation of Trustee’s Income Trust property or funds that are transferred to a trustee for management are not considered income or property of the trustee. However, any allowances or commissions that the trustee receives from managing the trust are taxed as income. The trustee must follow the general rules on expenses outlined under Cambodian tax law to record all income and expenses related
May 28, 2025
Tilleke & Gibbins attorneys in Vietnam have contributed the 2025 edition of Doing Business in Vietnam, a comprehensive Q&A-style resource from Thomson Reuters Practical Law that provides essential insights for companies navigating business operations in Vietnam. The guide presents a detailed overview of the country’s legal framework and regulatory environment, reflecting recent updates in Vietnamese legislation and practice. This annually updated guide offers key information on the following areas: Legal system: Structure of the Vietnamese judiciary and the role of codified law. Foreign investment: Conditions for market access, licensing requirements, foreign ownership restrictions, and investment incentives. Business vehicles: Formation and operation of legal entities, including limited liability companies, joint-stock companies, and representative offices. Employment: Employment contracts, social insurance, labor rights, and procedures for hiring foreign nationals. Tax: Overview of corporate income tax, personal income tax, value-added tax, and other tax obligations. Intellectual property: Procedures for protecting and enforcing patents, trademarks, copyrights, and other IP rights. Data protection: Compliance requirements under Vietnam’s data privacy laws, including the Personal Data Protection Decree. Competition law: Antitrust rules and regulatory oversight under the Law on Competition. Anti-bribery and corruption: Legal framework and enforcement practices aimed at curbing corrupt activities. E-commerce and digital business: Regulations governing online platforms, digital content, and cross-border services. Marketing and advertising: Laws and guidelines on advertising standards and consumer protection. Product regulation and liability: Safety requirements, product liability issues, and roles of relevant authorities. Doing Business in Vietnam is part of Practical Law’s global series of legal guides designed to support international practitioners and businesses. To access the most recent edition of the Vietnam guide, visit the Practical Law website and sign up for a free trial.
May 2, 2025
Attorneys from Tilleke & Gibbins have updated the latest edition of Doing Business in Thailand, a Q&A-style guide from Thomson Reuters Practical Law that offers an overview of key legal considerations for companies operating in jurisdictions worldwide. The contribution outlines the country’s legal and regulatory framework for foreign investment and business operations and reflects the latest legislative developments. The chapter addresses the following core topics: Legal system: Structure of the courts and the codified nature of Thai law. Foreign investment: Business restrictions under the Foreign Business Act, sector-specific regulations, exchange control rules, and investment incentives. Business vehicles: Overview of partnerships, private and public limited companies, and other legal entities. Employment: Labor protections, employment contracts, foreign worker requirements, and termination procedures. Tax: Corporate and personal income tax, indirect taxes, and tax obligations for residents and non-residents. Intellectual property: Registration and enforcement of patents, trademarks, designs, and copyrights. Data protection: Key provisions of the Personal Data Protection Act and related compliance obligations. Competition law: Regulatory framework under the Trade Competition Act. Anti-bribery and corruption: Relevant legislation and enforcement mechanisms. E-commerce and digital business: Legal regime for online transactions and digital platforms. Marketing and advertising: Consumer protection laws and regulations affecting advertising and marketing practices. Product regulation and liability: Safety standards, liability regimes, and roles of enforcement authorities. Practical Law, a legal reference resource from Thomson Reuters, publishes a range of guides for hundreds of jurisdictions and practice areas. The insurance and reinsurance guide is a valuable resource for legal practitioners, covering numerous jurisdictions worldwide. To view the latest version of the guide, please visit the Practical Law website and enroll in the free Practical Law trial to gain full access.
March 13, 2025
Vietnam’s Ministry of Finance has released a draft Decree on Tax Administration for E-Commerce and Digital Platforms (“Draft Decree”), introducing significant tax compliance obligations that could reshape how digital platforms, and individuals and business households conducting business through the platforms, manage their tax responsibilities. Aimed at strengthening tax enforcement, the Draft Decree requires e-commerce and digital platforms to actively track and withhold taxes from business households and individual sellers, and remit payments to tax authorities. While it has not yet been promulgated, the Draft Decree is expected to take effect on April 1, 2025, leaving platforms with a limited window to prepare for compliance. Who Is Affected by the New Tax Rules? The Draft Decree significantly broadens the tax administration scope beyond traditional e-commerce platforms to cover a wide range of digital economy participants. Specifically, the Draft Decree places direct tax-related responsibilities on two major categories (collectively, “Regulated Operators”): E-commerce and digital platforms with payment functions (e.g., platforms that process buyer payments via e-wallets, bank transfers, cards, or cash-on-delivery); and Other digital-economy players that enable e-commerce transactions, including (i) intermediary service platforms connecting service providers with consumers, (ii) digital content platforms, (iii) online advertising providers, (iv) cloud computing and data storage providers, (v) social media platforms engaged in business activities (e.g., live-stream, in-app transactions), (vi) online education, gaming, and digital entertainment platforms generating revenue from digital transactions, (vii) Vietnam-based partners of foreign digital service providers facilitating local payments for overseas platforms, and (viii) intermediary payment service providers handling financial transactions for e-commerce activities. Under the Draft Decree, Regulated Operators will be required to track, report, and enforce tax compliance for both resident and nonresident individuals and households conducting business through their platforms (“Sellers”). What New Tax Obligations Do Platforms Face? Onshore platforms For the first time, Regulated Operators will
AWARDS & RANKINGS
December 17, 2025
Tilleke & Gibbins is pleased to announce that Jay Cohen and John Frangos have been recognized in the Lexology Index: Client Choice 2026 report as two of the world’s leading practitioners in their respective fields. Jay Cohen is recognized for his work in franchising, while John Frangos is cited for outstanding work in investigations. The Client Choice awards highlight lawyers who stand out for excellence in client care and the quality of their service. Established in 2005, Client Choice is distinctive in that winners are selected solely based on nominations from corporate counsel. Only one lawyer per practice area is recognized in each jurisdiction. This recognition reflects sustained commitment that Jay and John have shown to delivering practical, client-focused advice and achieving strong outcomes across complex and often sensitive matters. The full Lexology Index: Client Choice 2026 results are available on the Lexology website.
December 12, 2025
Tilleke & Gibbins has maintained its strong market position in the newly released Chambers Asia-Pacific 2026 rankings, with six Band 1 honors in core practices and consistently strong performance across the entire region. In addition to the exceptional practice-area rankings, 33 lawyers were recognized across 11 practice areas.
December 1, 2025
Tilleke & Gibbins is pleased to announce that the firm has been honored with two awards at the 2025 Lexology Index Awards in London, this time picking up both the Thailand and Vietnam Country Awards. Formerly known as the Who’s Who Legal Awards, the Lexology Index Awards celebrate outstanding achievements by firms and individuals identified through Lexology’s extensive global research process. Tilleke & Gibbins’ continued success in this forum reflects the exceptional expertise and dedication of its team, whose commitment to delivering the highest caliber of legal services continues to set a benchmark in the industry. The firm extends its gratitude to its talented professionals and valued clients for their continued trust and support. A full list of the winners of the 2025 Lexology Index Awards is available on the Lexology website.
November 20, 2025
Tilleke & Gibbins is pleased to share that Asia Business Law Journal (ABLJ) has released its A-List of Thailand’s Top 100 Lawyers and its exclusive Legal Icons list for 2025. This year, Darani Vachanavuttivong has again been named a Legal Icon, recognizing her as one of the most distinguished professionals in Thailand’s legal community. In addition, nine other Tilleke & Gibbins lawyers have been named among Thailand’s Top 100 Lawyers. The full list of honorees is: Alan Adcock Charunun Sathitsuksomboon Chusert Supasitthumron (new ranking) Athistha (Nop) Chitranukroh Darani Vachanavuttivong (Legal Icon) Kobkit Thienpreecha Nuttaphol Arammuang Pimvimol (June) Vipamaneerut Thawat Damsa-ard Tiziana Sucharitkul The ABLJ A-List is compiled through extensive research, including nominations and feedback from in-house counsel worldwide and international law firm partners who focus on Thailand. The editorial underscores the demand for lawyers with unmatched expertise, a dedication to quality, and a proven ability to deliver strategic, innovative solutions. To view the full list and the accompanying editorial analysis, please visit the ABLJ website.