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Baker McKenzie’s specialised tax group advises on the transactional work the firm undertakes, but the team also has expertise in wealth management and tax planning for corporates and high-net-worth individuals and, moreover, prides itself on its formidable contentious tax practice. In one particularly high-value matter, Panya Sittisakonsin acted for Boon Rawd Brewery in the tax structuring aspects of its cross-border acquisition of a 25% stake in Masan Consumer Holdings and a 33% stake in Masan Brewery for $1bn. Sittisakonsin also acted alongside Nopporn Charoenkitraj to represent NMB-Minebea in a Supreme Court case, in which the team was able to convince The Revenue Department of Thailand to waive surcharges on unpaid tax for companies with more than one Board of Investment certificate. The department has also acted for clients such as 3M Thailand and Pepsi-Cola (Thai) Trading in customs and excise cases, which are particularly challenging cases in Thailand, given the country’s customs assessment procedures. Principal partner Kitipong Urapeepatanapong is a key contact.

A boutique tax outfit, LawAlliance Limited is regarded by its peers as one of the premier tax practices in the Thai marketplace. Acting for domestic and international clients, the firm handles the gamut of corporate tax issues, from structuring M&A and corporate reorganisations, to finance and securities taxation, to individual investment and capital gains tax, to tax disputes. The team is jointly led by Piphob Veraphong, who has experience in contentious and non-contentious tax issues, and Thanasak Chanyapoon, who has expertise in the tax aspects of structured finance and securities transactions, e-commerce and debt restructuring. Prangtip Anantavipat and Rachanee Prasongprasit are active associates in the practice group.

In all regards’, the tax team at Tilleke & Gibbins is ‘simply excellent’. The department not only supports the firm’s corporate and M&A transactions, but runs an active and diverse tax advisory practice, with experience in a wide range of industry sectors, including manufacturing, consumer goods, energy and financial services. Additionally, the tax group regularly teams up with the firm’s highly rated dispute resolution department to handle complex tax litigation. Sriwan Puapondh heads the tax department and regularly provides tax advice to international clients such as Azbil and Zuellig. The team is increasingly active in the tax aspects of construction and infrastructure projects, and in 2016-2017, Puapondh advised clients such as Skidmore, Owings & Merrill and China Petroleum Pipeline Bureau on construction projects in Thailand. In the banking and finance space, the team provides regulatory tax advice to the Central Bank of Norway regarding synthetic stock lending transactions involving shares in Thai listed companies. Working alongside the disputes resolution department, the tax team is also involved in an extremely high-value customs duty case.

With particular expertise in customs duties and associated regulatory compliance, Blumenthal Richter & Sumet Ltd is instructed by a host of import/export clients across a range of industry sectors, including pharmaceuticals, energy and mining and automotive. Headed by Sumet Mingmongkolmitr, the team is also active in tax structuring, especially as it pertains to foreign investment. He recently handled tax planning issues for clients in the oil and energy sector and continues to be involved in multiple long-running disputes with Thailand’s Customs Department. The department also advises on indirect taxation, transfer pricing and international tax treaties. Senior associate Promboon Sookatup is also recommended.

DLA Piper (Thailand) Limited provides ‘clear and pragmatic advice’ in non-contentious tax structuring and optimisation, as well as tax disputes, including those involving customs and excise duties. The Bangkok team regularly works alongside its regional colleagues, and is led by Chanvitaya Suvarnapunya, who has particular experience in the tax aspects of large cross-border M&A. In 2016-2017, Suvarnapunya has provided tax advice to regional investment managers, manufacturers and professional services firms. On the contentious side, Peter Shelford successfully represented Diebold Nixdorf in two claims brought by the Thai Customs Department regarding the import duties and taxes imposed on certain ATM machines; in addition to these two claims, there are five more ongoing claims. Notable clients include St Jude Medical, Cognizant Technology Solutions and ACI Worldwide (Thailand).

With a strong Thai presence and a fully integrated regional network, DFDL has experience in domestic and ASEAN taxation and is especially well-known for its tax expertise in cross-border M&A and international tax planning for both inbound and outbound corporate clients. Laos-based Jack Sheehan, who leads the regional tax department, acted for Metal Tiger on the tax aspects of its acquisition of a joint venture mining project, corporate restructuring and proposed AIM listing. Similarly, the team has advised real estate clients on the tax implications of delisting from the Thai stock exchange and also has experience in energy taxation. Nipaporn Supha-Utchaichan and Jonathan Blaine are also key contacts.

Hunton & Williams’ tax department has experience in a wide range of tax matters, including cross-border tax planning and litigation, but it specialises in the tax structuring of corporate reorganisations and capital markets transactions. The team is led by Chinawat Assavapokee, who has particular experience in tax issues affecting the oil and gas, telecoms and IT sectors. He recently advised Star Gas Co on the tax planning of its entire business transfer in the region, and acted for Nathalin Co on the tax aspects of an investment and subsequent business restructuring prior to its IPO. Saravut Krailadsiri is an active associate in the tax group. Sermsang Power Corporation, SEA Limited and Turnkey Communication Services are among the department’s notable clients.

The lawyers at Lorenz & Partners Co., Ltd. have experience in domestic and international tax panning for foreign corporate investors and European expatriates in Thailand. Recent examples of the team’s work include handling the tax structuring of Winterhalter’s consolidation of local entities and advising Andritz Hydro on the tax aspects of renovating a hydro-power plant in Thailand. Naowarat Suthiweerawat is a key contact in the department, and additional clients include Foodpanda and Voith Hydro Shanghai.

Siam Premier International Law Office Limited’s tax department is best known for advising domestic Thai clients on the tax aspects associated with investment structuring and restructuring, M&A and other corporate transactions. Practice head Praphan Phichaiwatkomol advised Thaisri Insurance on its tax options in relation to a corporate restructuring and assisted Satyabutr with the tax incentive requirements of its entire business transfer. Additional clients include Thai Dairy Industry, Amata B.Grimm Power and Tipco Foods Public Company.

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