22nd Annual Conference

Registration

Speaker:

• Somboon Weerawutiwong
  Tax and legal Leader, PwC Thailand

Speaker:

• Somsak Anantawat
  Deputy Director, General of the Revenue Department

The ever evolving landscape of tax regulations in the wake of the COVID-19 pandemic is undeniable. Businesses are experiencing a rapid transformation in the digital realm, necessitating swift adjustments in tax provisions. In this session, we’ll offer a comprehensive overview of the latest tax updates that could impact your business to ensure you stay informed and prepared for the digital revolution.

In addition, there are notable changes to the duty imposed on cross-border trade. The Carbon Border Adjustment Mechanism (CBAM) is one of the key mechanisms under the EU ESG concept which impacts Thai businesses. As a starting point, Thai exporters of steel, aluminium, cement, fertiliser and electricity to the EU will need to work with EU importers for quarterly reporting on production information and carbon emissions. EU importers who can’t get the required information or who don’t meet the threshold will have to pay additional duties.

We’ll also highlight Thai customs matters and audit trends as many companies are currently challenged at ports or audited by the Customs Audit or Investigation Teams for incorrect HS codes, customs valuation, and the most recent, non-compliance with regards to duty privileges (BOI). The financial impact for non-compliance with customs regulations can be significant as Customs can assess the retroactive duties for three to five years, plus a maximum of twice-imposed fines. We’ll provide you with customs insights and share experiences in this section.

Speakers:

• Somboon Weerawutiwong
  Tax and legal Leader, PwC Thailand
• Tuttapong Kritiyutanont
  Tax and legal Associate Partner, PwC Thailand
• Tanarat Permpoonsap
  Tax and legal Senior Manager, PwC Thailand

After one year of PDPA enforcement, there’s some subordinate legislation that business operators should be aware of: data subjects’ complaint criteria and procedures of the authority, exemption for recording the data processing activities of small business operators, data security measures for data controllers and data breach notification criteria and procedures, and cases reported to the PDPC. We’ll discuss updates on cases that fall under GDPR and US regulations, as well as privacy trends in Asia.

Speakers:

• Vunnipa Ruamrangsri
  Tax and legal Partner, PwC Thailand

Coffee break

There’s been a tax debate surrounding the New Merger and the amendments to the Civil and Commercial Code (effective as of 7 February 2023). Although no amendments to the Revenue Code or written guidance have been issued, we’ll share some notable tax and legal points under the New Merger scheme. 

In addition, we’ll briefly touch on common tax issues which may arise from various business integration methods, taking into account your commercial objectives to determine the most suitable method for you.

Speakers:

• Vanida Vasuwanichchanchai
  Tax and legal Partner, PwC Thailand
• Vunnipa Ruamrangsri
  Tax and legal Partner, PwC Thailand
• Pimprapai Silawatshananai
  Tax and legal Director, PwC Thailand

For entrepreneurs and businesses, the age-old dilemma of choosing between debt and equity funding has remained a fundamental decision when embarking on business ventures. However, impending shifts in tax practices in Thailand, influenced by global trends such as the introduction of financial service transfer pricing (FSTP) by the OECD, have brought new dimensions to this decision-making process. These changes have not only raised questions about the effectiveness of previously employed tax planning strategies which thrived – possibly due to legal ambiguities – but might have also rendered them obsolete.

The objective of this session is to revisit the timeless question on capital structuring and to give updates on regulations and on how to integrate emerging trends. By proactively staying informed on these upcoming changes, companies can position themselves to weather the evolving tax landscape, adapting and thriving in a future where concerns about the Revenue Department’s shifts in tax practices due to global changes will no longer cast a shadow of uncertainty.

Speakers:

• Orawan Fongasira
  Tax and legal Partner, PwC Thailand
• Nopajaree Wattananukit
  Tax and legal Associate Partner, PwC Thailand
• Weeraphat Srivanichakorn
  Tax and legal Director, PwC Thailand

Lunch

(Please select one of these sessions)

Session A: Empower a brighter future by reinforcing current tax compliance: Common tax compliance pitfalls.

In anticipation of an upcoming wave of new tax regulations, many companies have shifted their focus towards preparing to adapt to these changes. However, this heightened focus on new regulations has, in some instances, led to the neglect of compliance requirements that already exist, possibly due to legal ambiguities, the tax authority’s unexpected interpretations or improperly designed tax practices and policies.

This session aims to foster the exchange of experiences, highlighting common pitfalls, addressing frequently misunderstood topics. It will also be an opportunity to share interesting matters that raise awareness, enhance your current tax compliance and pave the way for a brighter future.

Speakers:

• Niphan Srisukhumbowornchai
  Tax and legal Partner, PwC Thailand
• Tuttapong Kritiyutanont
  Tax and legal Associate Partner, PwC Thailand
• Jareeporn Phongsuriyanunt
  Tax and legal Director, PwC Thailand
• Thidaporn Chatchaiyadej
  Tax and legal Director, PwC Thailand

(Please select one of these sessions)

Session B: Navigating the changing landscape of international taxation – BEPS, MLI, and the Two-Pillar Solution to implement a global minimum tax and the reallocation of global taxing rights.

Thailand’s adoption of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) means that many of the tax treaties that Thailand is a counterparty to have been amended.

Additionally, the OECD’s Two-Pillar Solution will bring the more-than-century old international tax rules up to date and will apply to large MNEs.

• Pillar One, intended for 2025, aims to ensure a fairer profit distribution by reallocating taxing rights to market jurisdictions.
• Pillar Two, effective as of 2024, implements a global minimum tax of 15%. The rules will introduce a mechanism for groups to pay a top-up tax in jurisdictions where their effective taxes fall below the minimum rate.

Taxpayers should evaluate these new rules and assess the impact as soon as possible, given the pace at which many of them are being implemented.

Speakers:

• Orawan Phanitpojjamarn
  Tax and legal Partner, PwC Thailand
• Panachai Anontanut
  Tax and legal Partner, PwC Thailand
• Jirapong Kitsanayanyong
  Tax and legal Director, PwC Thailand
• Sukrit Srisakulchawla
  Tax and legal Senior Manager, PwC Thailand

Coffee break

The tax and legal landscape is changing faster than ever and staying compliant can feel like a major challenge.

Today’s tax and legal functions are facing unprecedented levels of external pressure and internal challenges to meet the increasing demands being placed on them to do more with less. Regulatory requirements are becoming increasingly complex. There’s also more need for information transparency, and both tax authorities and management boards are demanding that risks are effectively managed. This constantly changing environment is driving companies to reimage and transform their businesses.

In this session, we’ll examine how having a robust tax policy and tax control framework can help manage your internal tax risk profile. Also, we’ll look at how we can harness the power of technology and artificial intelligence to drive greater efficiency, improve processes, manage risks and help drive greater value for the tax and legal functions.

Speakers:

• Vunnipa Ruamrangsri
  Tax and legal Partner, PwC Thailand
• Wutinon Trisrisak
  Tax and legal Associate Partner, PwC Thailand

Higher visibility for taxpayers’ related-party transactions and other transfer pricing data have intensified transfer pricing audit cases over recent years. Meanwhile, having robust transfer pricing documentation alone is never sufficient for taxpayers to withstand transfer pricing audits without a hefty tax liability – which in turn creates double taxation for groups. Taxpayers should be well aware of what options are available to address double taxation.

During the session, we’ll go through recent transfer pricing audit cases and demonstrate how costly it is when faced with transfer pricing assessments. We’ll also share with you alternatives to resolve cross-border disputes and how to prevent transfer pricing disputes from happening in the first place with the Bilateral Advance Pricing Agreement (BAPA).

Speakers:

• Janaiporn Khantasomboon
  Tax and legal Partner, PwC Thailand
  
• Panachai Anontanut
  Tax and legal Partner, PwC Thailand

Speaker:

• Somboon Weerawutiwong
  Tax and legal Leader, PwC Thailand