Insights

This tax news will be of interest to: Thai companies that are part of multinational enterprise (MNE) groups and engage in intercompany transactions. Introduction The Thai Revenue Department (TRD) has implemented an artificial intelligence (AI)–driven big data analysis system to improve operational efficiency, review taxpayers’ data, and assess potential risk areas or red flags. The system classifies taxpayers as either “good” or “risky”. If potential red flags are detected, the system notifies the TRD to consider initiating a tax audit. You may refer to our transfer pricing (TP) series Part 1: Potential Red Flags. In addition, the TRD has recently launched the QUICK BIG WIN scheme, which allows eligible taxpayers to receive tax refunds within a significantly shortened timeframe and without undergoing a tax audit if they meet the scheme’s criteria. This aims to enhance taxpayer liquidity and support business operations.

In recent months, I’ve written about what it takes to create real momentum within organisations: how leadership, structure, process, and culture each play a role in determining whether the strategy translates into performance. But as we enter the final quarter of the year, I find myself reflecting on something even more fundamental.

This tax news will be of interest to: Thai companies that are part of multinational enterprise (MNE) groups and engage in intercompany transactions. In our Part 3: we have provided guidance on how companies can minimise risks during a tax/TP audit related to intra-group services, as well as examples of evidence and supporting documents. In this article, you will find guidance on how to minimise risk related to royalty transaction.

Last month, we talked about structure, how the way you organise your business should serve your strategy, not the other way around. But there’s something even more invisible, yet equally critical, shaping whether strategy turns into real results. And that is culture.

Thailand’s newly amended Organic Act on Anti-Corruption (No.2) B.E. 2568 (2025) marks a significant shift in corporate compliance expectations. With expanded whistleblower protections and stricter enforcement mechanisms, companies operating in Thailand must act swiftly to align their internal controls and reporting systems with the new legal landscape.

Cloud & Software Services and Withholding Tax: Where Does Thailand Draw the Line?

Last month, I wrote about how the right leaders, those who truly move the needle, are rarely out there looking for jobs, but they are always listening for the right opportunity. Attracting such high-impact leaders is a powerful step forward, but it is only half the battle. Once those leaders join, the real question emerges: is your organisation designed to let them succeed?

This tax news will be of interest to: Thai companies that are part of multinational enterprise (MNE) groups and engage in intercompany transactions. In the TP series Part 1 & Part 2: we have highlighted the potential red flags and how to deal with transfer pricing (TP) audit. The main focus of the Thai Revenue Department (TRD) is on intra-group services, which we will cover in this article.

In Thailand’s fast-moving business environment, one truth is quietly shaping the success of transformation and growth: the leaders who can truly move the needle, those who can drive change, inspire teams, and navigate complexity, are rarely the ones applying for roles. They’re not browsing job boards. They’re not polishing their resumes. They’re deep in the business of leading. But they are listening for the right opportunity, at the right moment, delivered by someone they trust.

Global Business in a New Risk Landscape Given the present level of technological development and economic volatility around the world, businesses are operating under immense pressure from all sides.

Not long ago, in a meeting with a group of senior executives here in Bangkok, I noticed something interesting. While everyone was talking about Generative AI, the opportunities, the fears, the future, very few were talking about leadership. How will we, as executives, actually lead in a world transformed by AI? It struck me that while AI advancing at incredible speed, leadership thinking must move even faster. This is not just another business trend. It is a profound shift - one that challenges how we define value, build teams, and set strategy. Here are a few thoughts I wanted to share.

In May, we explored how leadership must evolve in Gen AI. This month, I want to shift our focus to something equally fundamental but often ignored in transformation conversations: process. It's not technology, platforms, or automation. It's just a simple, clear human process, the way work actually happens, from the ground up.

The Thai Revenue Department (“TRD”) has announced the Emergency Decree on Top-up Tax, B.E. 2567 (2024) (“Top-up Tax Law”), which will be effective from January 1, 2025. Below is a summary of the key aspects of this law.

This tax news will be of interest to: Thai companies that are part of multinational enterprise (MNE) groups and engage in intercompany transactions. In our tax news, you will find a guide on how a company can deal with a transfer pricing (TP) audit. How to manage TP risks during the audit If the company faces one or more red flags according to our TP series Part 1: Potential Red Flags, the company needs to prepare for how to deal with the TP audit by the tax authority. To reduce the risk of TP adjustments during the TP audit, the following important steps should be taken:

Thailand’s Cabinet Approves Draft Financial Hub Act to Boost Global Investment To position Thailand as a key global financial hub, the Thai Cabinet approved the draft Financial Act on February 4, 2025, as proposed by the Ministry of Finance. This legislation seeks to attract foreign financial businesses to invest in Thailand, while simultaneously fostering the development of the nation’s financial industry, workforce, and infrastructure to meet international standards.

Fraud, theft, and other forms of wrongdoing present a major challenge for businesses in the information age. Whereas in earlier times, paper trails and physical evidence could often be relied upon to catch corporate criminals, the digital nature of both assets and spreadsheets allow would-be fraudsters to engage in more sophisticated levels of obfuscation. However, the same set of new technologies enables improved guardrails against such damaging activity. It is the responsibility of modern organisations to actively prevent fraud and theft from occurring within their ranks — either directly through internal procedures, or with the help of external specialists, or both.