Apichaya Dhanusiri is an associate in Tilleke & Gibbins’ Thailand tax practice. She advises multinational corporations and domestic clients on a broad range of Thai and international tax matters, with experience spanning tax advisory, mergers and acquisitions (M&A), transfer pricing, tax compliance, and BEPS 2.0 Pillar Two requirements. Her practice focuses on delivering practical and commercially driven tax solutions to clients across a diverse range of industries, including automotive, manufacturing, services, hospitality, telecommunications, data centers, e-commerce, and renewable energy.

Apichaya has extensive experience supporting domestic and cross-border M&A transactions, particularly in conducting buy-side and sell-side tax due diligence. She also advises clients on tax health checks, tax audits, and complex tax issues, helping businesses manage tax risks while supporting their commercial objectives.

Apichaya has worked on a wide range of transfer pricing and tax compliance matters, including benchmarking studies, functional and economic analyses, the preparation of transfer pricing documentation, and advance pricing agreement (APA) projects. Her experience helping clients navigate BEPS 2.0 Pillar Two requirements includes conducting impact assessments, reviewing transitional safe harbor eligibility, delivering technical training, and supporting local entities related to Pillar Two obligations.

Prior to joining Tilleke & Gibbins, Apichaya worked in the Bangkok office of a Big Four consulting firm. She holds an LLB in International Trade, Business, and Tax Law from Chulalongkorn University and is licensed by the Lawyers Council of Thailand.