Customs and trade services​

Custom & trade services

Overview

We are a dedicated team of professionals who provide assistance and guidance on all aspects of customs duty and excise tax management. Our wide range of services includes audit management/support, compliance health-check, and planning.

PwC Thailand helps businesses navigate the complexities of international trade compliance, including Thai customs and excise regulations.

We provide comprehensive advisory services including customs and excise compliance, tariff classification, valuation and leveraging customs privileges to optimise duty savings. Our team supports clients in managing customs and excise audits, resolving disputes and developing risk management strategies to minimise regulatory risks and operational disruptions.

By combining deep local expertise with PwC’s global network, we help multinational corporations, importers, exporters and logistics companies improve supply chain efficiency, ensure regulatory compliance and reduce cross-border trade costs.

Our services are designed to facilitate smoother customs operations and enable businesses to capitalise on trade opportunities in Thailand and the wider region.

Custom & trade services

Customs and Trade

1. Origin

Are you confident that your imports and exports under FTA privileges actually qualify for origin benefits?​

FTA usage has risen significantly in the past few years and has now become the norm. Companies using FTA privileges may not know whether the products’ origin actually qualifies, but they apply the privileges with the belief that the goods are entitled for preferential duties. It’s worth while to check your privilege usage to ensure that it’s compliant. Let us give you the confidence that you can continue to enjoy the privileges without disruption.​

Make sure your origin claims strong enough to withstand Customs scrutiny

Why origin matters more than ever

In today’s increasingly complex global trade environment, rules of origin play a pivotal role in determining whether your goods qualify for import duty reductions under Free Trade Agreements (FTAs) or can be recognised as ‘Thai-origin products’ for wider commercial and regulatory purposes.

However, there is no single, universal definition of what ‘origin’ means. Different trade schemes apply different rules, and the same product can be assessed differently depending on the jurisdiction, agreement or authority involved.

Where businesses get exposed

Many importers and exporters underestimate the risks hidden in origin determination. Applying the wrong origin criteria—or failing to support claims through robust cost structures and documentation—can trigger shipment delays, customs investigations and financial penalties.

These challenges are amplified when trading across multiple jurisdictions. Exports to the United States, for example, require Thai exporters to comply with both Thai Department of Foreign Trade regulations and the more complex rules of origin enforced by US Customs and Border Protection—often resulting in conflicting interpretations.

Turning compliance into opportunity

When applied correctly, preferential duty schemes under FTAs can significantly reduce import duties or offer exemptions. But any weak link in your supply chain—from incorrect origin qualification to poor documentation—can erode these benefits and result in import duty payback and penalties.

Free zone privileges at risk—do your manufactured products meet the 40% local content?

Are you applying free zone privileges correctly?

Are you currently applying free zone duty exemption privileges for domestic sales? If so, are you confident your free-zone manufactured products meet the 40% local content requirement?

Also, are you satisfied that the raw materials have undergone substantial processing to qualify as finished products?

Where risks commonly arise

In practice, more companies are applying free zone duty exemption privileges when removing imported goods into domestic sales without fully understanding the customs criteria used to calculate the 40% local content threshold. This includes how Customs assesses substantial production processes and the penalties imposed when imports are later found not to qualify.

Why this matters

To ensure compliance, businesses must clearly understand the relevant customs criteria and substantial production assessment—particularly to mitigate the risk of customs penalties.

How PwC Thailand can help

Our services cover: 

  • origin and free zone local content criteria identification
  • cost structure verification and recommendations for origin qualification.

If you’re uncertain whether your free zone practices would withstand Customs review, now is the time to reassess your approach before issues arise.

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Are you confident that your imports and exports under FTA privileges actually qualify for origin benefits?​

2. Classification​

When was the last time your import and export HS codes were reviewed?​

HS code classification is always burdensome and complex. Minor details of a product may affect the classification and potentially change the applied duty rates. Our classification specialists can help you evaluate your product’s details and give you peace of mind. We’ll advise whether your classification rationale is well supported or if you should use a different HS code.​

HS classification errors can trigger duty reassessments, penalties and delays

Why HS classification is critical

Customs classification under the Harmonised System (HS codes) is based on a standardised global numbering system that’s applied to all traded products. HS codes are critical as they determine the duty rates, trade statistics and rules of origin.

As a result, incorrect classification can lead to multiple adverse consequences.

Beyond duty rates

HS codes also guide licensing requirements under the Customs National Single Window platform, which facilitates import and export licensing procedures. Other trade measures—such as import quotas and the imposition of anti-dumping duties—are also based on classification of products. Critically, preferential origin relies on the correct use of HS codes, and an incorrect code can lead to the rejection of a Certificate of Origin.

Why this matters

Errors in HS classification can affect far more than duty rates. They can trigger licensing issues, impact trade remedies, and expose businesses to compliance risk and Customs challenges across their supply chain.

How PwC Thailand can help

Our services cover: 

  • HS code determination
  • advance classification ruling applications
  • support in classification disputes.

If you’re not 100% confident that your product classifications are correct and defensible, we recommend reviewing them before issues arise at the border or under audit.

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When was the last time your import and export HS codes were reviewed?​

3. Customs valuation​

Are you making overseas payments in addition to the selling price of imported goods?​

These payments include royalties, technical licence fees, design fees, or research and development fees that may be subject to duty under Customs law and need to be included in the import value. We’ll help you navigate these complexities so you can manage the customs valuation properly.​

Have you recently reviewed your transfer pricing policy from a customs perspective?​

The arm’s length principle of transfer pricing and the benchmarking analysis could be different. It can impact the import price of goods and the origin qualification of exported goods. We can review your approach to optimise your customs valuation policy.

Customs valuation is a high‑risk audit area—would your pricing positions stand up to scrutiny?

Where customs valuation issues arise

Customs valuation issues cover a wide range of technical areas, including:

  • the dutiability of royalties, technical licence fees, design fees and management fees
  • import and export price adjustments
  • Incoterms
  • acceptance of the price actually paid or payable
  • Free of charge goods, and dual pricing systems.

Why valuation is a high‑risk area in Thailand

In Thailand, customs valuation is a key audit focus for Customs authorities. The rules are complex, and companies often find it difficult to defend their valuation positions. So, we strongly recommend customs valuation planning and structuring to mitigate the risk of challenge.

Managing tariff exposure under US imports

Following the introduction of US tariffs—such as top-up tariffs on the normal rates and product-specific duties—a First Sale Rule (FSR) can help to mitigate tariff exposure. Under the FSR, US importers may declare the value of the first sale (the manufacturer’s sale to a middleman), rather than the last sale (the middleman’s sale to the US importer).

How PwC Thailand can help

Our services cover:

  • customs valuation position assessment
  • import price adjustment and self-disclosure support
  • advance customs valuation ruling applications
  • support in customs valuation disputes.

If your customs values are complex, judgment‑based or influenced by post‑import adjustments, we recommend reassessing whether your valuation approach would pass a Customs review.

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Customs valuation

4. Duty privileges​

Have you recently reviewed your customs duties payments?​

You may be missing out on potential duty-saving opportunities or may not be maximising duty-saving privileges for imported goods yet. Let us help you check your eligibility for exploring potential savings.​

Schemes include Free Zone, BOI promotions and duty drawback.​

Do you efficiently manage duty privileges?​

Each duty privilege scheme has different criteria and complex procedures to comply with. We can help you with the selection ofthe most effective duty privilege for your business to explore duty-saving opportunities.​

Choosing the wrong duty privilege structure can erode or eliminate expected savings

Understanding Thailand’s duty privilege options

Thailand offers multiple import duty privilege options. Commonly used schemes include the Board of Investment (BOI), free zones, duty drawback and Free Trade Agreements (FTAs).

The selection and structuring of these privileges depend on several factors, including the nature of business or transactions, operating location, import-export orientation and the level of duty savings available.

Why careful assessment is essential

As a first step, businesses should carefully assess the relevant conditions, requirements and eligibility criteria. This enables a proper feasibility study, supported by a cost-benefit analysis, to evaluate both financial impacts and operational implications before enjoying the benefits.

How PwC Thailand can help

Our services cover:

  • feasibility study and cost-benefit analysis of the duty privileges
  • compliance risk assessment of the existing privileges
  • support in end-to-end implementation phases.

If your current duty privilege structure hasn’t been reassessed against changing business operations or regulatory expectations, we recommend reviewing whether it’s still appropriate and sustainable.

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Duty privileges​

5. Import/export licensing​

Are you sure that you’ve obtained all the necessary licences for your imports and exports?​

Failure to obtain appropriate licensing for your imports or exports can lead to the seizure of goods or a fine equal to the value of the goods. We’ll help you identify import or export licensing requirements governed by Thai authorities.​

Missing licences can stop shipments at the border—do you have all the required import and export licences?

Understanding the National Single Window

Thai Customs has developed a National Single Window (NSW) online platform to integrate import and export licensing requirements from other government agencies with customs clearance. Currently, more than 30 government bodies link import or export licences through the NSW.

Why licence reviews remain critical

Despite the NSW platform, business must still perform a comprehensive review of product specifications to confirm whether licences apply and which types are required.

In the worst-case scenario, failure to obtain the correct import or export licence could result in shipment delays and potentially surrendering the goods or a fine equivalent equal to the value of the imported goods.

How PwC Thailand can help

Our services cover:

  • import/export licensing requirement identification
  • best practice recommendations to obtain the licences
  • support in licensing disputes.

If you haven’t recently reviewed your licensing requirements against current product specifications and agency requirements, we recommend reassessing your approach immediately before issues arise.

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Import/export licensing​

6. Excise tax​

Incorrect SRP calculations are common, and it can lead to excise tax penalties and surcharges

Understanding excise tax in Thailand

Excise tax in Thailand is a government-imposed tax on:

  1. domestically manufactured goods when they’re removed from the factory or
  2. specific imported goods, such as liquor, beverages, tobacco products, fuel, batteries and motor vehicles.

Excise tax rates vary by product. The tax may be ad valorem (a percentage of the price), specific (a fixed amount per unit) or a combination of both.

How the tax base is determined

The scope of excise tax continues to expand. Today, excise tax is calculated using the suggested retail price (SRP), not the import price or the ex-factory price. To support this, the Excise Department requires a detailed cost breakdown of the SRP under a prescribed cost structure.

Incorrect SRP calculations can lead to underpaid tax, penalties and surcharges. Planning ahead is also critical, particularly in anticipation of impending changes that may require adjustments to product formulas.

We can help you understand the excise rules, structure your SRP correctly and plan ahead—so you avoid penalties and unexpected costs.

How PwC Thailand can help

Our services cover:

  • excise tax health-checks
  • excise tax planning including SRP recommendations
  • support in excise tax disputes.

If you’re uncertain whether your excise tax positions, or SRP calculations, would withstand review by the Excise Department, we recommend reassessing your approach to avoid unexpected tax exposure.

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Excise tax​

7. Export control​s

Are you prepared for enforcement of export control measures?​

Export control is a regulation issued to control dual-use items, which are goods that can be used for both civilian and military purposes. In the future, any changes to the enforcement landscape (e.g. licensing control) can impact your operations, and non-compliance could disrupt your export supply chain. You also could be subject to certain penalties. A well-structured Internal Compliance Programme (ICP) can help you to mitigate risks. We can evaluate your compliance with export controls and recommend changes you should make to your ICP.​

Export controls rules are expanding—do your exports comply with the new requirements?

Understanding Thailand’s export control framework

Thailand’s export controls are governed by the Control on Weapons of Mass Destruction—Related Items Act B.E. 2562 (2019) (TCWMD)

The Act regulates the export of military, strategic and dual-use goods. The Department of Foreign Trade (DFT), under the Ministry of Commerce, administers export licensing and enforcement.

Recent developments and expanding scope

In the first quarter of 2026, the DFT began imposing export licence requirements for the first time, initially covering nuclear-related products. Exporters may need to obtain licenses before exporting controlled dual-use items.

The scope of export licensing will expand to additional product groups, including aerospace, marine and navigation-related products, in subsequent phases.

Why early preparation matters

Exporters should therefore prepare early by reviewing product classifications and validating your products and your end-users. Failure to do so may result in compliance gaps as licensing requirements continue to expand.

How PwC Thailand can help

Our services cover:

  • reviewing the product status under the TCWMD regulations
  • ICP preparation and application
  • support in preparing future TCWMD implementation.

If you haven’t yet assessed whether your products or customers fall within the scope of current or upcoming export controls, we recommend reviewing your exposure as soon as possible before licensing requirements expand further.

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Export control​

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Contact us

Paul Sumner

Paul Sumner

Tax and Legal Partner, PwC Thailand

Tel: +66 (0) 2844 1000

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