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The Central Tax Court overrode the previous decision on determination of profit and loss of BOI prom

The Central Tax Court has recently overrode their previous ruling in the NMB Minibea Case on determination of profit and loss of a business obtaining an investment promotion from the Board of Investment (BOI), upholding the criteria and methods prescribed by the Revenue Department (RD). A BOI promoted business is generally entitled to exemption from income tax, reduction of tax rate upon expiration of the exemption period, as well as utilization of the net loss incurred during the promotion period to offset against the net profits gained after the end of the exemption period. Absent exact methods for determination of profit and loss of the promoted business for taxation, the BOI and the Reve

Judicial general anti-avoidance rules (GAAR) emerged in Thailand.

Judicial general anti-avoidance rules (GAAR) have emerged in Thailand, so its time to refresh your mindset on taxation. In the recent decades, many countries and international organizations have been very active in developing tools to tackle tax avoidance. These tools can be divided into specific anti-avoidance rules (SAAR) which address specific taxpayers or transactions and the much broader GAAR. In the strict sense, a GAAR can be described as “statutory” anti-avoidance rules legislated to combat any perceived tax-avoidance situation. It principally enables the tax authorities to deny tax benefits or disregard the legal form of any transaction for tax purposes, regardless of its legality a

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