Legal advice, tax structuring, transaction support services and business matchmaking on FinTech, cryptocurrency and digital asset ventures

PUGNATORIUS Ltd. is the Bangkok-based specialist provider of transactional legal and tax advice on foreign investments in Thailand’s manufacturing and service industries as well as property developments and acquisitions.

Thailand is well-positioned to be the region’s next Fintech hub as digital convergence continues to spread in a rapidly changing financial services industry. The Bank of Thailand (BOT) has taken a leading role in creating an enabling environment for FinTech expansion in Thailand. Thailand even plans to use blockchain technology to improve conventional banking services.

The law firm is the trustworthy advisor for strictly confidential legal and tax advice and support, focussed on foreign entrepreneurs and cryptocurrency UHNWI’s, based on a deep knowledge of the tax and regulatory framework, and backed by a wealth of practical experiences to skillfully manage and command digital asset projects in a multi-currency, multi-legislation and multi-business environment as well as applying licenses for ICO portals, brokers and traders.

Seven areas of legal support and tax advice in the FinTech industries

Free industry updates and professional considerations on cryptocurrencies, digital asset businesses, financial service ventures and other FinTech segments are available on the firm’s webpage and at our bibliographical reference. These posts can provide only a low-resolution snapshot and are neither deemed to be legal advice nor do they result in an attorney-client relationship.

PUGNATORIUS Ltd. provides legal and tax services on a wide range of cryptocurrency matters. Professional assignments, based on a paid consultancy agreement, cover mainly these seven areas:

#1. Thai crypto-compliant company formations: Set-up of companies in compliance with the rules and regulations for digital asset businesses, ICOs, financial services and other FinTech activities. 

While standard nominee company structures will hardly get the approval by the SEC, even preference share structures as described in “Company formation in Thailand” have to be adjusted to meet the regulatory standards.

To establish a crypto-company under the U.S. Thai Treaty of Amity and under the investment promotion scheme by the BOI are other challenges which require a well-considered approach.

#2. Regulatory-avoiding and tax-efficient cross-border structuring: The law firm advises on the set-up of digital coin businesses in offshore jurisdictions and crypto-friendly legislations, the outsourcing of tasks and activities to an offshore location and the operating of international ventures from Thailand. It offers an in-depth  comparison and pre-selection of different offshore locations and transaction management of the whole set-up process.

The PUGNATORIUS group provides transaction support services for the company formation and company secretary service in Bahamas, Barbados, BVI, Cayman Islands, Chile, China, Curacao, Cyprus, Dubai /VAE, Hong Kong, India, Ireland, Luxembourg, Malta, Mauritius, Netherlands, Nevis, New Zealand, Panama, Seychelles, Singapore, Spain, Switzerland, and Uruguay.

#3. Digital asset and financial services licensing: The law firm advises on the preparation and application for digital business licenses as an exchange, trader, broker, ICO portal, etc.

Apart from crypto-fintech, the law firm advises and supports securities business license type A, B, C and D, the business license to undertake advisory services, securities borrowing and lending, as well as to undertake venture capital management.

This includes the legal and tax support on the mining of Bitcoin and altcoin in Thailand and abroad.

#4. Blockchain and ICO advisory services: Based on extensive experiences in the FinTech sectors, the law firm advises on the most streamlined way to successfully accomplish an ICO, acts as CLC chief legal counsel (“gatekeeper”) respectively CLO chief legal officer for cryptocurrency ventures, advises regarding digital asset compliance, legal validity, and economic feasibility, to identify and avoid the 95% of ICOs which are doomed.

#5. Thai and cross-border tax structuring: As renowned tax counsel, PUGNATORIUS advises on cryptocurrency taxation and a tax-efficient structuring of Bitcoin and Altcoin transactions regarding

  • Personal income tax (PIT) implications for casual Bitcoin users, investors, and speculators,
  • Corporate income tax (CIT) implications for cryptocurrency and other digital asset ventures
  • Withholding tax (WHT) obligations
  • Value-added tax (VAT) implications

Also, the tax counsel advises on tax structuring and asset protection schemes, especially the use of offshore jurisdictions, the tax-efficient restructuring of existing cryptocurrency wealth structures and digital asset ventures, the taxation of cryptocurrency losses, and internationally recognized asset protection schemes.

Advice on domestic and cross-border tax optimizing for ICOs and digital asset businesses on the corporate level and from the investor’s viewpoint. The Bangkok law firm gives full disclosure for clients abroad, which tax structuring opportunities in Thailand with its territorial tax system and unique taxation principles enable to be washed clean of past sins.

Cryptocurrencies, same as offshore companies, do not base their eligibility on anonymity and masking of ownership. Instead, they allow a smart tax planning and investment structure to obtain various benefits fully in compliance with the law. Legal and tax advice on digital coins are not at all assistance in crime.

#6. Cryptotransaction support services: The law counsel supports and assists in a highly confidential manner to transfer cryptocurrencies into fiat money, real estate or other real-world assets in a tax-efficient and compliant structure (crypto2fiat, btc2cash). Cashing out Bitcoins and cryptocurrencies in private banks.

The law firm appreciates the opportunity to discuss trustee services, authorized representative duties, the support of offshore cryptocurrency cold storage arrangements, and other asset protection and tax planning schemes on a highly confidential basis.

#7. Legal opinions and professional statements: The law firm is available for legal opinions on legal and tax aspects of cryptocurrency and digital asset projects. This includes professional statements on the regulatory character of utility tokens, asset-backed coins, the applicable laws and regulations in a cross-border digital venture, and the need for licenses and approvals.

PUGNATORIUS can guide your crypto project through the red-tape requirements, legal hurdles and industry practice in Thailand. Up-to-date information about the legal and regulatory framework of Thailand’s digital asset markets. Independent advice on risks and opportunities. Lessons you do not want to learn the hard way. A specific consultancy agreement is available on request.


No information, opinions or other matter contained in the site shall be interpreted as an invitation, offer or suggestion to buy or sell financial services or transactions of any kind. PUGNATORIUS Ltd. does not provide investment, legal or tax advice through its website and nothing herein should be construed as being financial, legal, tax or other advice whatsoever.

Blockchain, stakehodler, Bitcoin, Ethereum, Ripple, Bitcoin Cash, EOS, Litecoin, Cardano, Stellar, IOTA, TRON, Neo. BX Wallet, Bitcoin Thailand, Coins.co.th, LocalBitcoins. crypto derivatives. Bank of Thailand, FinTech regulatory sandbox. commercial central bank digital currency (CBDC).