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Apichaya Dhanusiri

Associate

Biography

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.

Experience

  • Advised on the tax due diligence and transaction structuring aspects of a multibillion-baht acquisition of a leading hospitality and hotel portfolio in Thailand, enabling the investor to successfully complete the transaction with a clear understanding of key tax risks and liabilities.
  • Represented a leading global Japanese electric motor manufacturer in tax and transfer pricing audits, successfully reducing the potential tax exposure from approximately THB 40 million to THB 7 million through strategic audit defense and negotiations with the Thai tax authorities.
  • Led a comprehensive tax health check for a leading electric vehicle manufacturer in Thailand, identifying key tax risks and recommending governance enhancements to strengthen compliance and mitigate future exposures.
  • Advised a multinational renewable energy group on the Thai tax implications of internal restructuring involving the transfer of power generation assets, power purchase agreements, and related project rights.
  • Advised on tax due diligence for the proposed acquisition of insurance businesses in Thailand and Vietnam, identifying key tax risks and transaction considerations to support a cross-border insurance-sector transaction.
ABOUT Apichaya

Location

Languages

    Thai

    English

Insights

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.
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.
December 15, 2023
As part of its membership in Lex Mundi, Tilleke & Gibbins has published an updated edition of its Guide to Doing Business in Thailand for 2023. This guide outlines the key factors for starting and operating a business in the Thai market. Issues covered include: Investment incentives Financial facilities Exchange controls Import and export regulations Structures for doing business Requirements for the Establishment of a Business Operation of the Business Cessation or Termination of the Business Labor legislation, relations, and supply Tax Immigration requirements This publication is part of Lex Mundi’s Country Guides series prepared by member firms in more than 100 jurisdictions worldwide. The guides serve as a useful resource for planning international business strategy and researching new markets. The full Guide to Doing Business in Thailand is available through the button below.
September 19, 2022
Tilleke & Gibbins’ insurance specialists in Cambodia, Laos, Myanmar, Thailand, and Vietnam have contributed to the Subrogated Recoveries – Asia Pacific guide produced by RPC Premier Law Firm. The guide addresses how insurers can recover indemnifiable losses. For each jurisdiction in the Asia Pacific region, the guide addresses the following topics: Local legal framework on subrogation; Insurers’ right to subrogate; Investigations prior to subrogated proceedings; Limitation period for subrogated action; Responsibility for costs in subrogated action; Enforcement of judgements for insurers; and Subrogated actions against co-insured parties. The Subrogated Recoveries – Asia Pacific guide is available below.

Awards & Rankings

July 22, 2026
Tilleke & Gibbins has been named Best Insurance Law Firm in Thailand in the InsuranceAsia News Country Awards for Excellence 2026. This is the firm’s first recognition from InsuranceAsia News, and Tilleke & Gibbins was the sole law firm honored in the Thailand awards. The award recognizes the strength of Tilleke & Gibbins’ insurance practice and the team’s work advising clients in the sector. InsuranceAsia News selected the winners based on submission reviews, independent research, market knowledge, and analysis by the publication’s judging panel. InsuranceAsia News provides news, analysis, and market intelligence for insurers and related organizations across Asia. For more information and to view the full list of winners, please visit the InsuranceAsia News website.
April 3, 2026
Tilleke & Gibbins is pleased to announce that the firm has been shortlisted in two categories at the Financial Times (FT) Innovative Lawyers APAC 2026 awards: Innovative Lawyers in Cyber and Data Privacy – “Digital Identity & Cryptocurrency Compliance” Innovative Practitioner – Athistha (Nop) Chitranukroh The FT Innovative Lawyers APAC Awards recognize law firms and practitioners who are driving innovation in legal services and delivering innovative client solutions across the Asia-Pacific region. This recognition marks our third acknowledgment in the Innovative Lawyers category and, notably, our first-ever nomination in the Innovative Practitioner category at the FT Innovative Lawyers APAC awards. It reflects our team’s continued ability to support clients on groundbreaking, forward-looking projects across the region. The awards ceremony will take place on May 14, 2026, in Hong Kong. To learn more about the FT Innovative Lawyers APAC 2026 awards and to view the full list of shortlisted organizations, please visit the FT website.
March 19, 2026
Tilleke & Gibbins has been recognized in 17 categories at the 2026 Thailand Law Firm Awards from Asia Business Law Journal (ABLJ), up from 10 categories in 2025. The awards highlight leading law firms in Thailand across a broad range of practice areas, as well as overall firm performance. This year, Tilleke & Gibbins was named a co-winner in the Best Overall Law Firm category as well as in the following practice-specific categories: Artificial Intelligence Aviation Blockchain & Digital Assets Competition & Antitrust Data Compliance & Cyber Security E-Commerce, Digital Trade & Platform Regulation ESG (Environmental, Social, and Governance) Fintech Healthcare & Life Sciences Insurance & Reinsurance IP Litigation IP Prosecution Labour & Employment Private Equity & Venture Capital Shipping & Maritime Technology, Media & Telecommunications The awards are determined through ABLJ’s independent research, which considers recent work, client feedback, and market standing. The annual Thailand Law Firm Awards recognize firms demonstrating strong performance and breadth of expertise across key practice areas. For more details and the full list of winners, please visit the ABLJ website.

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