Past experience

 

n  Tax practice

 

§    Advising and assisting a Thai family in estate planning over assets located within and outside of the country by using an offshore trust.

 

§   Advising and recruiting a reputable Thai Chinese family in dividing the billion-baht family business and assets among family members amicably in the most time efficient manner.

 

§   Acting as legal counsel to a major Thai family group on asset management issues. Representation includes assisting with tax planning, diverse compliance issues, and corporate restructuring.

 

§    Reviewing the business structure of a leading Thai agro-industrial business group listed on the Stock Exchange of Thailand before advising on the appropriate shareholding structure, financial structure and business models that will yield the most effective tax rate for the group, and eventually assisting the group in the implementation of the agreed actions in the proposed tax planning scheme.

 

§    Assisting a Swiss Company in a turnkey project with the Electricity Generating Authority of Thailand, particularly on the permanent establishment (PE) issue, withholding tax refund, and request for a ruling from the Thai Revenue Department.

 

§    Assisting a leading Thai-based multinational agro-industrial group in determining the transfer prices in accordance with the arm’s length principle suggested by the transfer pricing guidelines of the Organization of Economic Cooperation and Development.  In addition, preparing a Transfer Pricing Master File , that will be retained centrally, and using such documentation to prepare local Thai and overseas entities in Indonesia and Singapore.

 

§    Assisting a French-US telecommunication company in making appeals against the assessment of the Revenue Officials on a permanent establishment (PE) issue.

 

§   Assisting Thai entities of a leading Japanese industrial conglomerate in preparing Thai transfer pricing documentation as required by the Japanese tax authorities through the parent company and advising the Thai entities on possible changes in the group’s transfer pricing policies as well as the necessary course of action to be taken to manage any repercussions from the Thai tax perspectives.

 

§  Reviewing the transfer pricing policy and analyzing the relevant financial information of a Thai manufacturing entity of a leading Japan-based sport equipment group, advising on the transfer pricing audit procedures, making assessment on the Revenue officers’ possible actions, and assisting the company in negotiating with the Revenue officers during the transfer pricing audit.

 

§   Advising and assisting a Thai subsidiary of a leading Japanese multinational automotive group in recovering and gathering necessary documents which were totally damaged by staff in the company’s redundancy program up to the adequate and satisfactory level as well as successfully defending their VAT position which resulted in a savings of over Baht 200 million in tax liability.

 

§    Assisting several subsidiaries of multinational companies and Thai companies in tax investigations by the Revenue Officials and customs investigations by the Customs Officials, including one active case being assessed in an amount of approximately US$ 25 million.

 

§   Assisting a client in the petroleum industry in successfully defending their tax position in a sale and lease back transaction and closing several billion Baht exposure.

 

§    Advising a client in the canned food industry in reviewing their supply chain and group structure in order to improve their overall tax efficiency.

 

§    Assisting several clients in different industries claiming income tax and VAT refunds in the range of 74-92% of the total refund claimed.

 

§    Advising a client in the petroleum industry to undertake an entire business transfer with tax privilege claim.

 

§  Assisting several clients in handling tax investigations during the liquidation process