There are three main types of tax audits (tax investigations) that are conducted by the Revenue Department's tax audit officers in Thailand.

Business Operation Visit (BOV) Audits

• A routine audit conducted under Section 88/3 of the Revenue Code;
• For the purpose of "reviewing" tax compliance and correct payment of tax.

Under Section 88/3, the Revenue Department's tax audit officers have the power to enter a place of business for the purpose of determining whether the business has complied with its tax obligations under the Revenue Code, and the power to request the owner of the business or a person present at the place of business to do as the tax audit officers consider necessary for this purpose.

Tax Refund Audits

• A tax refund audit conducted under Section 27 Qtr of the Revenue Code;
• For the purpose of "auditing" a tax refund claim.

Under Section 27 Quarter, the Revenue Department's tax 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 provide testimony and documents and records for inspection as the tax audit officers may deem appropriate.

Tax Investigations Under Summons

• A detailed audit of all types of tax payments conducted under Sections 19, 88/4, 91/21 and 123 of the Revenue Code;
• For the purpose of a detailed "investigation" of all of the tax payments for the previous 2 fiscal years, or for the previous 5 fiscal years when the tax audit officers have evidence or suspicion of tax evasion. 

Investigations under Summons are conducted when the 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 to appear for providing statements, accounting records, documents and other evidence for investigation for the previous 2 fiscal years, or for the previous 5 fiscal years when tax audit officers have reason to believe a taxpayer intentionally evaded tax.

For the tax penalties and surcharge applying under the above investigation types, you can refer to our Tax Penalties and Surcharge Tax Insight.

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