Showing 1 - 10 of 11
Determination of Section 40(8) income
Business, Lawalliance Limited Company, Published on 22/08/2017
» The government recently introduced a tax incentive programme to encourage individuals, including ordinary partnerships and groups of persons, to reorganise their businesses and operate them in the form of a company limited or a juristic partnership. This would make it easier to screen them for tax compliance, given the need to prepare statutory accounts.
Tax issues and business transfers: the devil is in the details
Business, Lawalliance Limited Company, Published on 25/07/2017
» Ever since tax incentives for business reorganisation were introduced two decades ago, different issues have arisen intermittently, especially as they relate to an entire business transfer (EBT), which has become a popular practice.
Changing rules for applying foreign tax credits
Business, Lawalliance Limited Company, Published on 12/07/2017
» One of the original principles outlined in the OECD Model Tax Convention is that no taxpayer should be taxed repeatedly on the same amount of income earned from a cross-border transaction. This situation is referred to as "juridical double taxation" -- where income is subject to taxes under the jurisdictions of more than one state.
Cross-shareholding rules and dividend tax exemptions clarified
Business, Lawalliance Limited Company, Published on 19/04/2017
» Most people are aware that there are two major types of double taxation for income tax purposes. The first is juridical double taxation, in which one taxpayer is taxed twice on the same amount of income by two different jurisdictions. This is normally dealt with in the context of double-taxation agreements.
Turning entrepreneurs into corporate entities
Business, Lawalliance Limited Company, Published on 07/03/2017
» February was a busy month in terms of new tax legislation. But this is just the beginning, as the director-general of the Revenue Department has also announced an ambitious plan to study extending Thailand's tax jurisdiction to overseas traders in cross-border e-commerce transactions. The idea is to generate tax revenue from online businesses, as the current legislation does not allow Thailand to tax foreign traders not doing business within the country.
E-payment and bank secrecy: what's next
Business, Lawalliance Limited Company, Published on 17/05/2016
» It has long been understood that a taxpayer has the right to a contractual arrangement that will allow him or her to incur the lowest tax cost where possible. Nothing in past constitutions or the new draft requires Thai nationals to choose a transaction that would expose the parties to the heaviest tax burden, as long as the transaction is within the law.
Expenses paid to 'unidentifiable' parties
Business, Lawalliance Limited Company, Published on 23/02/2016
» All business enterprises from time to time may encounter a situation in which they make payments to a recipient, but its identity cannot be proved to the satisfaction of tax authorities. We are not talking about a payment made in a sham transaction simply to receive a tax deduction but a payment that completely fulfils the cardinal rules such as those made on an arm's-length basis and exclusively spent for business purposes.
When will a liquidator be released from tax liability?
Business, Lawalliance Limited Company, Published on 26/01/2016
» When a life ends, whether that of a person or a business, it does not mean tax liability will also end. Dissolution and liquidation of a company are part of many corporate reorganisations, and in our experience this often requires the liquidator to make a speedy distribution of cash and other assets to shareholders. Thus, it is necessary for the liquidator to understand what he has got himself into.
Capital increases under the microscope
Business, Lawalliance Limited Company, Published on 24/02/2015
» Over the last couple of years, tax practitioners have become increasingly aware of suspicious or shady transactions, especially those without a genuine intention, being challenged more frequently by the Revenue Department.
Royalty taxes in a digitised society
Business, Lawalliance Limited Company, Published on 28/08/2012
» With nearly 8.7 million user accounts, according to a global survey earlier this year, Bangkok has the largest city Facebook population in the world. Most users these days possess devices that allow them to be online anytime, anywhere, 24 hours a day. To enrich their online lives, countless applications both paid and free are at their fingertips from online digital media stores.