Tax Audit & Appeal Representation
ตัวแทนสอบภาษีและอุทธรณ์ (Tax Audit & Appeal) · § Litigation
Quick Answer
Respond to summons → negotiate field audit → receive assessment → 30-day committee appeal → 30-day Tax Court petition.
Timeline: Field audit 3–9 months · committee appeal 6–12 months · Tax Court 12–24 months · Supreme +12 months.
Official fee: Tax Court filing fee THB 200 flat · no 50% deposit required if filing to court.
Legal Basis
Revenue Code §88/2 (VAT) + §19–20 (income tax) + §30 (30-day appeal) · then Central Tax Court (file within 30 days of ruling) · assessment prescription 2 years (5 years for intentional evasion).
Who Needs This
Companies served RD summons · reassessed taxpayers · MNEs challenged on TP.
Required Documents
- Summons + assessment
- 5-year financials + GL
- Contracts + invoices
- TP documentation (if any)
Common Pitfalls
- Accepting audit summary without negotiation = overpaying unnecessarily.
- Missing 30-day appeal = assessment final · assets seized immediately.
- Failing to separate factual vs legal issues = losing on appeal.
Typical Use-cases
- 5-year VAT reassessment
- TP challenge on intercompany royalty
- Personal tax reassessment from crypto
FAQ
- Deposit before appeal?
- No · security only needed to defer collection.
- Can we settle with RD?
- Yes · field audit allows negotiation · penalties/surcharge reducible.
- Is Tax Court single-instance?
- No · 3 levels — Central Tax Court → Special Case Appeal → Supreme Court.
Other Legal Services
Request a quote — Call 083-249-4999 · LINE @NYC168 · contact@ilc.ltd






