Maximising Shareholder Value

Panel discussion by The Revenue Department

In this session, the Revenue Department officer will share the most important tax developments in Thailand, so that you can prepare for the upcoming changes.

Transforming tax through data and technology

As the global tax landscape becomes increasingly complex, tax functions face mounting pressure to deliver accuracy and compliance to stakeholders. This session explores how organisations can leverage data and technology to enhance tax compliance, meet complex regulatory requirements, and strengthen their overall tax function.

Thailand tax, legal and customs update

New policy initiatives, legislative developments, and administrative guidance are reshaping Thailand’s tax landscape. Understanding which changes matter most, and how they could affect your organisation, is critical for managing risk and identifying opportunities.

In this session, we’ll examine the regulatory developments that business leaders should have on their radar, including:

• Tax developments: ESG and sustainability-related measures, e-Donation incentives, withholding tax, OECD accession updates, and notable tax rulings—including the new merger scheme. 
• Nominee shareholding companies: The Department of Business Development (DBD) has introduced a series of legislative reforms to counter the surge in nominee shareholding registrations. We’ll discuss the DBD’s interpretation of foreign participation in Thai companies, and the new criteria for executive positions held by foreign nationals.  
• International trade: We’ll provide essential updates on the Trump Tariffs, including the US court ruling that suspended the original 19% top-up tariff. We’ll also discuss Thailand’s export control regime for dual-use items, which came into effect in June.  
• Excise taxes: Following the government’s recent initiatives, we’ll discuss the potential expansion of the excise tax scope and key regulatory updates. 

Join us as we discuss the practical implications of these developments and the actions businesses should consider to stay compliant, manage risk and respond effectively to regulatory change. 

Breakout session 1 (Please select session A or B)

Session A: Domestic tax focus

How authorities are using technology for greater transfer pricing and customs scrutiny

The Revenue and Customs departments are transforming their approach to audits, using digital tools and data analytics to identify risks and review documentation. As audit activity becomes more targeted, understanding current enforcement trends and areas of scrutiny is critical for effective risk management and audit readiness.

This session will explore how recent transfer pricing and customs audits are evolving in Thailand, highlighting areas attracting increased scrutiny. We’ll share insights from recent audit experiences, and practical approaches to managing risk and improving audit preparedness.

Key takeaways

• How technology and data analytics are changing audit selection and risk assessment
• The transfer pricing and customs issues most likely to attract regulatory attention
• Customs implications of transfer pricing adjustments and intercompany pricing
• Practical steps to strengthen audit readiness and manage transfer pricing and customs risks

Breakout session 1 (Please select session A or B)

Session B: Overseas investment

M&A, Pillar Two and Transfer pricing: Essential considerations for growth abroad

As Thai multinationals pursue growth through overseas acquisitions and investments, the tax implications are increasingly important to deal value and long-term returns. Decisions made during the acquisition process can have significant implications for future tax costs, compliance obligations and operational success.

This session will explore how tax considerations can influence overseas acquisitions and investments, from deal valuation through to long-term operations. Drawing on M&A tax, Pillar Two and transfer pricing perspectives, we will discuss the practical implications for businesses seeking to expand internationally and maximise the value of their investments.

Key takeaways

• Pillar Two influence on transaction structuring
• Key transfer pricing, financing and historical tax risks to identify during due diligence and target assessments
• Post-acquisition tax considerations, including supply chain, operating model and intellectual property alignment
• Practical approaches to preserving value, protecting synergies and managing cross-border tax risks

Breakout session 2 (Please select session C or D)

Session C: Domestic tax focus

Beyond compliance: Common tax pitfalls and Pillar Two considerations

In today’s fast-evolving regulatory environment, tax compliance has become a strategic business priority rather than a back-office function. As tax authorities increasingly use technology and data analytics to identify risks and target audits, businesses face growing pressure to strengthen compliance, governance and transparency.

This session will explore the common compliance pitfalls, frequently misunderstood issues, and Pillar Two consideration for Thai subsidiaries of multinational companies operating in Thailand. We’ll share practical insights and emerging trends to help you strengthen your tax compliance framework.

Key takeaways

• The most common tax risks and compliance pitfalls to avoid
• Practical insights on Pillar Two considerations for Thai subsidiaries of foreign multinational
• Steps to strengthen tax governance and compliance readiness

Breakout session 2 (Please select session C or D)

Session D: Overseas investment

Practical tax lessons for Thai multinationals across the business lifecycle

Expanding overseas through subsidiaries, branches, joint ventures or holding companies can create growth opportunities, but cross-border structures often contain hidden tax and customs costs. For multinational groups, success depends not only on understanding local rules, but also how they interact across jurisdictions.

In this session, we'll share practical lessons from managing overseas investments. Drawing on real-world experiences, we’ll explore the tax challenges that can arise across the investment lifecycle and their impact on long-term returns.

Key takeaways 

• Common tax risks and cross-border mismatches that can arise throughout the investment lifecycle from entry and funding to operations, profit repatriation and exit
• Considerations for managing business structures in line with evolving tax requirements