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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

March 12, 2025
In November 2024, Thai Prime Minister Paethongtarn Shinawatra unveiled ambitious plans to enhance tax incentives for foreign film productions during a networking reception in Los Angeles, coinciding with her visit to the APEC Economic Leaders’ Meeting in Lima, Peru. This event, attended by Motion Picture Association executives and leaders from top US film companies, marked a significant commitment to boosting foreign investment in Thailand’s film industry. Thailand’s Department of Tourism (DOT) prioritized the initiative by updating the Announcement on Guidelines, Procedures, and Conditions for Applying for Benefits Under the Incentive Measures for Foreign Film Production in Thailand in December 2024 to further position Thailand as a destination for large-scale international film and television productions. Key Amendments to Film Incentives under the 2024 Announcement The 2024 announcement introduced major changes, including (1) removal of the rebate cap, previously set at THB 150 million (approx. USD 4.5 million) per project, enabling rebates based on total qualified spending, and (2) an increase in cash rebate rates. The maximum allowable cash rebate rate was increased to 30 percent from the previous cap of 20 percent. The base rate of 15 percent remains unchanged. The primary incentive available under the 2024 announcement is a 15 percent cash rebate on qualified spending in Thailand of at least THB 50 million (approx. USD 1.5 million). On top of this primary incentive, additional incentives are available; however, the total possible cash rebate is capped at 30 percent, and the additional incentives can only amount to an added 15 percent. Also, the total rebate (including both primary and additional incentives) for films with a budget of less than THB 100 million (approx. USD 3 million) is capped at 25%. To obtain a higher rebate rate, productions may apply for the following additional incentives: Compliance Requirements Foreign production companies
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March 6, 2025
On February 18, 2025, the Thai Senate approved an amendment to the Act on the Establishment of and Procedures for the Tax Court. This follows the July 2024 approval by the Thai cabinet and subsequent preparation of supporting secondary legislation. This important amendment to procedural law, once it takes effect, will extend the exclusive jurisdictional powers of the Tax Court to all criminal tax, customs, and excise tax claims in addition to the court’s existing jurisdiction over all such civil claims. The amendment, while now formally approved by the legislature, is awaiting the king’s signature and will take effect 180 days after its publication in the Government Gazette. Based upon its projected publication date, the amendment will likely take effect by the end of the third quarter of this year. This development is set to offer a more sophisticated Tax Court litigation process for highly specialized and often complex criminal tax and customs claims, something with which Thailand’s traditional criminal courts have struggled. It also ensures that all tax and customs matters are adjudicated before the same court, saving time, party costs, and judicial resources. This appears likely to result in more consistent adjudication of criminal tax and customs disputes, a benefit for the Thai government and party litigants alike. Any ongoing criminal tax and customs claims already commenced with the respective criminal courts on the date on which the amendment becomes effective will remain under the exclusive jurisdiction of those criminal courts. The Tax Court will have exclusive jurisdiction over all other claims. This important legislative change offers those managing or otherwise facing civil and/or criminal Thai tax or customs disputes the opportunity to more effectively plan and execute a uniform defense strategy before a single, qualified forum.
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January 3, 2025
Thailand has adopted the OECD’s global minimum tax framework through the Emergency Decree on Top-Up Tax B.E. 2567 (2024). Published in the Government Gazette on December 26, 2024, this legislation implements a 15% global minimum effective tax rate for large multinational enterprise (MNE) groups. The emergency decree took effect on January 1, 2025. The emergency decree was enacted through expedited procedures to implement “pillar two” of the OECD’s Base Erosion and Profit Shifting (BEPS) 2.0 project’s Global Anti-Base Erosion (GloBE) Rules. This swift implementation ensures Thailand can collect relevant tax revenues and prevents potential revenue losses from MNEs that might otherwise shift profits to jurisdictions with lower tax rates or to countries that have already implemented similar top-up tax legislation. Key aspects of Thailand’s implementation of the global minimum tax through the emergency decree are described below. Top-Up Tax The emergency decree introduces a dual mechanism for collecting additional top-up tax from MNEs whose effective tax rate falls below 15%. The first mechanism is a domestic top-up tax that targets MNEs operating within Thailand when their local effective tax rate is lower than 15%. The second mechanism is the income inclusion rule, which determines when a company’s foreign income should be included in the parent (main) company’s taxable income. This rule applies to Thai-based entities—including ultimate parent entities (UPE), intermediate parent entities, and partially owned parent entities—that hold ownership stakes in low-tax foreign jurisdictions. Scope MNEs subject to Thailand’s implementation of the global minimum tax framework are defined in the emergency decree as those whose UPEs report consolidated revenue of at least EUR 750 million (approximately THB 28 billion) in at least two of the four accounting periods preceding the relevant fiscal year. Reporting and Payment In-scope MNEs must comply with specific reporting obligations to the Thai Revenue Department. The filing deadline is set
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December 4, 2024
Thailand Legal Basics, a valuable primer for foreign investors, explores all aspects of living and doing business in Thailand. Written by specialists at Tilleke & Gibbins in Bangkok, it is the only comprehensive English-language guide to the Thai legal system with a focus on the concerns of foreign business and investment.
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AWARDS & RANKINGS
October 17, 2025
Tilleke & Gibbins has once again secured its place as one of Thailand’s top tax law firms in the newly released ITR World Tax 2026 rankings, reflecting the firm’s ongoing dedication to delivering exceptional tax legal services. In the 2026 edition, Tilleke & Gibbins maintained its Band 3 rankings in three key categories for Thailand: Customs Transfer Pricing General Corporate Tax We’re also proud to share that two of our colleagues have been featured in the ITR World Tax Leaders list: Saravut Krailadsiri (Notable Practitioner) Kobkit Thienpreecha (Promoted Lawyer) The firm’s rankings affirm its role as a go-to partner for complex tax matters, driven by expertise, reliability, and strategic foresight. With deep regional expertise, the team helps clients structure investments, manage compliance, and optimize tax efficiency. Widely regarded as a definitive guide to the world’s top tax law firms, the ITR World Tax rankings draw on client feedback, peer recommendations, and extensive research to spotlight excellence across jurisdictions. For more information on World Tax 2025 and to explore the complete rankings, please visit the ITR World Tax website. To learn more about our tax capabilities, click here.
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September 12, 2025
The 2025/2026 edition of the IFLR1000 Asia-Pacific rankings, released by International Financial Law Review (IFLR), highlights Tilleke & Gibbins’ continued excellence in financial and corporate transactional work. The firm has maintained its strong rankings across multiple jurisdictions and practice areas while achieving notable upgrades and new recognitions, reaffirming its position as a leading firm in the Asia-Pacific region. This year, Tilleke & Gibbins received firmwide rankings in key jurisdictions, including: Thailand Banking & Finance—Tier 3 Capital Markets: Debt—Tier 3 Capital Markets: Equity—Tier 3 M&A—Tier 2 Project Development—Tier 2 Restructuring & Insolvency—Tier 3 Vietnam Banking & Finance—Tier 4 M&A—Tier 3 Project Development—Tier 3 Cambodia Financial & Corporate—Tier 2 Project Development—Tier 2 Laos Financial & Corporate—Tier 2 In addition to these firmwide rankings, Tilleke & Gibbins had several standout individual recognitions, with 12 lawyers honored in the 2025/2026 individual rankings—an increase from last year’s 10. This year’s results include upgraded rankings for John Frangos and new rankings for Charupat Boon-Long, Derrick Khoo, Prisna Sungwanna, and Saravut Krailadsiri. The full list is as follows: Charunun Sathitsuksomboon—Highly Regarded, M&A, Thailand; Women Leader Charupat Boon-Long—Rising Star, M&A, Thailand (new ranking) David Mol—Rising Star, Corporate and M&A, Cambodia Derrick Khoo—Rising Star (Partner), Financial and Corporate, Thailand (new ranking) Jay Cohen—Highly Regarded, Banking, Cambodia John Frangos—Highly Regarded, Restructuring & Insolvency, Thailand (upgraded ranking) Niti Muangkote—Rising Star, Financial & Corporate and Project Development, Laos; Highly Regarded, Banking & Finance, Thailand Prisna Sungwanna—Highly Regarded, Financial & Corporate, Laos (new ranking) Saithong Rattana—Notable Practitioner, Project Development and M&A, Laos Santhapat Periera—Highly Regarded, Banking & Finance and M&A, Laos; Highly Regarded, Banking & Finance, Thailand Saravut Krailadsiri—Notable Practitioner, Thailand (new ranking) Tram Ngoc Bich Nguyen—Highly Regarded, M&A, Vietnam To see the full set of IFLR1000 rankings for Tilleke & Gibbins’ jurisdictions, please see the Cambodia, Laos, Thailand, and Vietnam pages
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