Thailand: Clarifying aspects of tax audit protection program for SMEs

Thailand: Tax audit protection program for SMEs

The tax authorities in Thailand have clarified and expanded on the “tax audit exemption program” announced in early 2016 for small and medium size entities (SMEs).

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The program basically aims to provide incentives for SME taxpayers to regularize their tax affairs on a forward-looking basis, by providing protection from tax audits. Since being announced earlier this year, the tax authorities have expanded on the guidelines. Among the clarifications are the following:

  • The “tax audit exemption program” will not apply to withholding tax. Therefore an eligible taxpayer could still be subject to a withholding tax audit. 
  • An eligible taxpayer can still apply for the “tax audit exemption program” even if the taxpayer is currently subject to an audit investigation, under a summons or enquiry. In such instances, the audit investigation will continue for the specific period/year. 
  • An eligible taxpayer can still apply for the “tax audit exemption program” even if the taxpayer has or intends to file a claim for a tax refund. The Revenue Department can still, however, audit the period/year for which the refund has been claimed. 
  • In addition to the other qualifying requirements, taxpayers must have been incorporated at least 12 months before 31 December 2015. Therefore, a company incorporated on or after 2 January 2015 would not be eligible for the “tax audit exemption program.”• An eligible taxpayer that has been placed into liquidation or plans to liquidate will be disqualified from the “tax audit exemption program.”

Under the program, the following periods will be exempt from tax audits and investigations (other than those that are specifically excluded) in respect of: 

  • Corporate income tax—any accounting period starting before 1 January 2016
  • Value added tax, specific business tax (SBT) and/or stamp duty—any income, transaction or instruments before 1 January 2016


Read a February 2016 report prepared by the KPMG member firm in Thailand: Update on the ‘tax audit exemption program’ for taxpayers

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