Tax Investigations (Tax Audits) Conducted in Thailand
There are three main types of tax investigations (audits) conducted by Revenue Department tax audit officers in Thailand, as follows:
Business Operation Visit ("BOV") Investigations
Under Section 88/3, the Revenue Department audit officers have the power to enter a place of business for the purposes of determining whether the business has complied with the tax provisions under the Revenue Code, the power to request the owner of the business or the person present at the place of business to do as the audit officers determine necessary for the investigation, and the power to seize documents.
Tax Refund Investigations
Under Section 27 Quarter, the Revenue Department audit officers have the power to issue a written notice to a person claiming a tax refund or other person involved, requiring him or her to appear for giving statements and relevant documents and records for inspection, as may be deemed proper.
Tax Investigations Under Summons'
Investigations under Summons are conducted when the Revenue Department's tax audit officers have reason to believe that false or inadequate information has been reported in a tax return, for which the audit officers have power to issue a summons requiring a taxpayer or a witness to appear for providing statements or accounting records, documents and other evidence for investigation, for the previous two fiscal years, or the previous five fiscal years when the tax audit officers have evidence or reason to believe that a taxpayer intentionally evaded tax.
For details of the tax penalties and surcharge applying under the above investigation types, you can refer to our Tax Penalties and Surcharge Tax Insight Article.
This is a general information Tax Insight Article only. It should not be used to determine any particular matter without consulting with your experienced Thailand tax advisor.