International Tax Planning for Cross Border Transactions

In any cross border transaction, how the parties structure the considerations and features of a transaction will have the significant impact on parties’ tax burden on such transaction.

Our tax attorneys can help clients structure a cross border transaction and craft a contract to evidence such transaction in the most tax efficient manner, taking full advantage of double taxation agreements and tax incentive under the Revenue Code.

We are familiar with international tax planning strategies including transfer pricing, treaty shopping, thin capitalization, use of conduit offshore company, remittance of business profit and royalty.

Only the rightly worded contract and the real economic substance behind a transaction will help the international tax planning withstand any challenge from a tax audit.

International Tax Planning for Cross Border
Foreign Direct/Portfolio Investment

If multinational/international companies plan to do business here in Thailand, the choice of entities and structure will have the significant impacts on their tax burdens.

Proper international tax planning helps companies minimize their tax burdens as they remit their profit out of the country either as a management fee, a service fee, a royalty, an interest, or a dividend.

Our licensed Thai tax lawyers can advise clients on how to remit their profit out of Thailand in the least possibly taxed way. Generally, we first run economic analysis of our clients’ transactions in order to ensure that our proposed structure reflects the economic reality of our clients’ transactions.

Afterward we help the clients structure their transactions and select their choice of entities in the manner that minimizes their tax burdens, fully taking advantages of double taxation agreements, offshore company, and tax incentives available under the Revenue Code.

International Tax Planning for Local Transactions
and Investments

In certain local transactions and investments, the international tax planning may be used to minimize the tax burden of the parties/investors as well. The use of offshore company may be used to minimize the tax liability of certain local transactions and investments.

Our international tax planning services cover: