Tax controversy & dispute resolution

Today’s tax controversy landscape represents a perfect storm of competing factors. Being subjected to a tax audit by the Revenue Department is no longer the exception but the rule in the self-assessment regime that Thailand follows. We can work with you to:   

  • prevent tax disputes with Revenue officers and identify tax risks and exposures arising from tax compliance
  • manage the tax audit process
  • resolve tax disputes with the Revenue Department at the lowest level

Our approach to preventing, managing and resolving tax disputes would be as follows:

Pre-audit dispute prevention phase: ‘Getting ahead of the issue’ by proactively limiting tax risk

  • Build ‘defence strategies’ for tax audits and disputes
  • Negotiate pre-filing rulings and Advance Pricing Agreements
  • Conduct a mock audit or undertake a tax compliance review to identify tax risks and exposures, and developing and implementing options to mitigate those risks

Audit management phase: Streamlining the audit process and resolving issues at the lowest level

  • Participate in and/or conduct meetings with the Revenue officers
  • Review and/or prepare correspondence and related documents
  • Develop a detailed work plan in response to issues and impediments raised by the Revenue officers

Post-audit settlement/resolution phase: Exploring alternatives for tax dispute resolution and advocating for successful dispute resolution

  • Assist with the tax appeal and litigation processes
  • Assist with mutual agreement proceedings

Contact us

Niphan Srisukhumbowornchai

Tax and Legal Leader, PwC Thailand

Tel: +66 (0) 2844 1000

Sudarat Isarakul

Partner, PwC Thailand

Tel: +66 (0) 2844 1000

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