Thailand Tax Rulings
Tax Insight | June 2009
In Thailand, both Revenue Department tax audit officers and taxpayers use the Tax Ruling system to determine an issue.
That is, both Revenue Department tax audit officers and taxpayers request the Revenue Department's tax lawyers for a Ruling on a tax issue and the taxpayer's tax liability for that issue, and the vast majority of both (again) accept the Ruling as a form of "judgment".
International businesses should note that Tax Rulings are not "judgments", but are the opinions of the Revenue Department's tax lawyers ... similar to opinions rendered by lawyers in the private sector.
But whilst the legal status of Tax Rulings are only opinions, as they are the Revenue Department's tax lawyers' opinion (rather than opinions of private sector lawyers), for those cases that you believe the Revenue Department's tax auditors have determined an issue wrongly, they can be very powerful tools to use for defending tax audit investigation cases.
This Tax Insight is general information only. It should not be used to determine any particular matter without consulting with an experienced Thailand tax advisor.