Thai, international and offshore tax advice and cross-border tax planning support

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 acquisitions and developments. The tax counsel can efficiently and precisely set out a strategy to manage your ongoing tax exposure both locally and internationally, taking into account the bigger picture. The firm provides professional advice for mitigating taxation in an efficient, innovative and legal way. Since international tax issues can impact business operations anywhere around the globe, we maintain long-term, handpicked relationships with global affiliates that share our policy and standards.

International tax planning utilizes the fact, that international tax systems are not harmonized, and that each country provides a specific tax environment for local (and international) business activities. Non-application of the tools and modules of international tax planning instruments results in a voluntarily and unnecessarily high tax burden. The BEPS initiative (Base erosion and profit shifting) of the OECD is a game-changer to the tax world as we know it. International tax planning is placed on a new foundation. Ask us how BEPS will be a disruptive factor in your value chain strategy.

Domestic tax planning: PUGNATORIUS Ltd. advises on Thai and cross-border taxation for corporations and individuals. This includes asset protection for HNWI’s. Integrated tax planning advice is provided with respect to corporate structuring. real estate developments and other business areas. The tax advisory firm has specific know-how and experience regarding offshore companies and offshore tax planning. 

Personal income tax planning; Tax planning is not limited to corporations and multinational organizations. Personal income tax planning gains significant importance in the case of multinational families. Families with members, assets or income sources in different countries can benefit from tax planning instruments to avoid taxes on certain activities, to minimize the overall income tax liability and to shift the timing of a taxable event.

Thai tax advice and international tax planning

To break the rules you have to know them. Worldwide tax minimization, international tax planning for both corporate and personal needs including the use of offshore companies. The law firm offers tailor-made, flexible solutions in the following tax matters:

#1. Corporate taxation: Reorganization of corporations and partnerships, tax structuring advice for international groups, tax-efficient holding company locations. Transfer pricing strategies, arm’s length principles. Contract manufacturing and toll manufacturing, stripped or limited risk distributorship schemes, tax-efficient lump-sum turnkey contracts. BEPS, Base erosion and profit shifting strategies. Compliance with anti-abuse and GAAR general anti-avoidance rules. Support and assistance in tax audits and dealings with the Thailand Revenue Department. Preparation of PIT statements through an affiliated accounting firm.

#2. Project-based taxation: Tax-efficient structuring of cross-border investments, including the optimum use of tax treaties, foreign tax credits, tax deferral, and entity classifications. Worldwide tax minimization, international tax planning for both corporate and personal needs including the use of offshore companies.

#3. Personal income taxation: Comprehensive professional advice and assistance for foreigners living in Thailand – whether working or not. Holistic cross-border tax planning, advice on reporting requirements. Tax advice and transaction support services with respect to banking introductions in Thailand and abroad, cryptocurrency and foreign exchange issues. Structuring of the dependencies between tax laws and the cross-border family and inheritance legislation. Preparation of PIT statements through an affiliated accounting firm.

#4. Land and Building Tax Act: Tax planning regarding the new property tax framework that replaced the archaic House and Land Tax as of 1932 and has the intention to improve and encourage land use, to enable more efficient tax collection, to increase public revenue, and to reduce income disparity. The new legislation replaces the previous flat rate of 12.5% by a progressive rate calculated on property usage. 

#5. Offshore taxation: Advice on the selection, formation, and operation of offshore companies. The integration of offshore companies in the cross-border value-added chain respectively individual wealth planning and asset protection.

The firm provides strategic international tax advice and individually tailored tax planning solutions for the needs of a demanding corporate and private clientele from all over the world. Security in an insecure tax environment. Tax strategies for challenging times.

Each case is different. Telephone inquiries and ad-hoc email requests on Thailand’s legal and regulatory framework without details and documentation are not accepted by the law firm. Individual support and professional advice are available under a paid consultancy agreement only.