Tax Advisory & Planning

Tax filing is execution: preparing and submitting monthly and annual returns (PND 50, VAT, WHT). Tax advisory is design: structuring transactions and operating decisions before they happen so the tax outcome is defensible and optimal. Most companies need both — compliance to file correctly, advisory to ensure the structure that generates those returns was right in the first place.

Yes. Under the Emergency Decree on Top-Up Tax B.E. 2567 (effective 1 January 2025), if your Thai effective tax rate falls below 15% — which a BOI tax holiday typically produces — a Qualified Domestic Minimum Top-Up Tax (QDMTT) applies. The BOI's 2025–2026 realignment introduced the Qualified Refundable Tax Credit (QRTC) for R&D, skill development, and productivity investments specifically to preserve incentive value within Pillar Two. Plizz models the QDMTT exposure and assesses QRTC eligibility before recommending whether to retain, restructure, or convert the BOI status.

Two thresholds matter. The Transfer Pricing Disclosure Form is mandatory for companies with annual revenue at or above THB 200 million that have related-party transactions — filed within 150 days of year-end alongside the CIT return. TP Documentation (master file, local file, comparables study) does not have a strict revenue threshold for preparation, but the Revenue Department can request it within 60–120 days of the Disclosure Form filing. The failure penalty under Section 71 Bis is THB 200,000 per failure — separate from any pricing adjustment or surcharge. Most CFOs of THB 200M+ companies treat documentation as standing infrastructure, not project work.

The Revenue Department disregards it. The burden of proof flips to the taxpayer — you must demonstrate arm's-length pricing without the documentation structure. If the Revenue Department raises an assessment, the penalty is 200% of the tax shortfall plus a 1.5% per month surcharge. The time to prepare TP documentation is before the transaction, not after the audit notice.

Often, yes — through the Thailand–Singapore Double Taxation Agreement (signed 2015, effective 11 January 2017). Under the treaty, qualifying intercompany royalties are reduced to 5%, 8%, or 10% depending on the type of intellectual property licensed. Treaty access requires substance, proper documentation, and a Certificate of Tax Residency from the Inland Revenue Authority of Singapore filed with the Thai Revenue Department before the payment. The position must be documented at payment time, not retroactively.

Three differences. Operating-level judgment — Plizz's founders Benoît Meneau and Jérôme Le Louer are former CFOs at listed companies across SEA, South Asia, Middle East, and Africa; advice is filtered through what this does to the P&L, working capital, and audit relationship, not just what the code says. Cost discipline — Plizz is typically 30–50% of Big-4 fees for comparable Thai-jurisdiction work, with named senior partners on the engagement. Cross-border reach — DFK International membership provides coordinated tax advisory across 100+ countries.

A freelance consultant typically delivers a one-off opinion. A firm engagement comes with documented working files, a named senior partner, professional liability insurance, audit-ready documentation, and continuity if a person leaves. For positions that need to survive a Revenue Department audit 2–3 years later, the firm's working file is what defends the position — not the email thread with a freelancer.

Yes — Revenue Department audit and assessment defence is a separate add-on engagement, quoted per case. Plizz maintains working files for every advised position so the audit response is grounded in the original analysis rather than reconstructed under deadline pressure. Plizz does not advise positions it is not prepared to defend.

Sometimes. Section 170(2) of the Revenue Code allows taxpayers to request advance rulings on uncertain tax issues, and a favourable ruling provides binding certainty. Practical caveat: Thailand's formal Advance Pricing Agreement (APA) framework for transfer pricing remains less developed than in the US, UK, or Japan; informal guidance is more commonly available. The ruling timeline is typically 3–9 months and needs to fit the transaction calendar. Plizz assesses whether the certainty premium justifies a ruling submission before recommending one.