THAILAND

BDO provide the full range of domestic and international tax services. International services which are many and varied include:

• Advising overseas investors on international tax regulations
• Developing cross boarder planning ideas that may be utilised in multiple jurisdictions
• Providing advisers experienced with transfer pricing, and having significant world wide expertise in documentation and pricing analysis
• Advice to high net worth individuals and executives moving across jurisdictions
• Assisting clients with the complexities that can arise when investing in a foreign jurisdiction by way of acquisition of an existing business, or the development of a new operation.

BDO Member Firm tax advisers in each country work together to ensure that all clients obtain the optimum tax position, taking into account the implications of the domestic laws in each country, and relevant double tax treaties. Properly structured cross boarder transactions can result in significant tax savings for clients, and subsequent increases in earnings per share. Such structuring may involve the use of hybrid structures; debt financing; royalty conduit arrangements; and optimum use of tax concessions in the particular countries.

International Tax Steering Committee

BDO International is a recognised leader in the provision of international tax services.
We have access to the network of BDO offices and experience around the world to ensure that
where necessary input from an international perspective or relevant specialist assistance is
obtained. By working closely with BDO International ' s Centre of Excellence that consists of a
group of experienced international tax practitioners from BDO member firms in 15 countries,
our clients can be assured that they will receive the services with reliability and at the highest
standard.

International tax services are promoted and supported by the BDO Tax Steering Committee
and Centres of Excellence, dedicated to keeping BDO Member Firms abreast of the latest
developments and ideas in international taxation.

These centres are responsible for monitoring and assisting BDO Member Firms in their area of expertise, and for providing a technical resource that can be utilised on an international basis.
The international tax expertise in BDO Member Firms is also enhanced by a structured programme of education and training, involving a number of international tax seminars during the year, and the creation of a "Think Tank" for the development of cross boarder tax planning ideas (TPIs).
 

Multinational tax challenges are among the most complex and potentially expensive issues facing companies with international operations.

At the same time, this complexity provides ample opportunities to optimise profits, increase cash flows, and moderate taxes for the astute tax professional. One of BDO International's missions is to assist your company through the myriad of international tax rules, especially as they pertain to international transfer pricing issue.

Transfer prices between related parties - and their potential impact on profits reported in different tax jurisdictions - have become of increasing interest to international tax authorities in an effort to protect their respective country's tax base. Most industrialized countries adhere to the transfer pricing guidelines of the Organisation for Economic Cooperation and Development, which require that intercompany prices comply with the "arm-length" standard (i.e., a price that would have occurred in a marketplace transaction between two unrelated parties).

Some countries require that documentation be prepared contemporaneously with the filing of tax returns. Multinational companies that have not complied with the documentation requirements are potentially exposed to significant penalties and double taxation if a tax authority reassesses income as a result of a transfer pricing adjustment.

How Does Transfer Pricing Affect Your Companyω

Transfer pricing affects your company and its affiliates if these entities:

• Exchange goods;
• Develop, own, or share intangible property (e.g., technology and know-how, trade secrets, trademarks, trade names, copyrights);
• Provide or receive services (e.g., managerial, administrative, technical, sales and marketing);
• Extend or borrow intecompany loans; or
• Share in the research and development of intangible property.

• Intangible holding company structures
• Intangible property valuations and buy-in payments
• Cost sharing arrangements
• Market-share strategies
• Mergers and acquisitions ("M&A") due diligence services

Compliance Products

• Documentation studies (global and country-specific)
• Advance Pricing Agreements ("APAs")
• Intercompany policy and implementation guidelines
• Intercompany agreements

Audit Defence Support

• Tax authority response and negotiations
• Dispute resolutins
• Competent Authority submissions
• Litigation support and testimony

This network includes experienced transfer pricing economists, international tax professionals, and financial analysts in numerous countries to provide your company with global resources and reach.

BDO Member Firms have extensive experience in structuring inbound and outbound transactions, and developing objective transfer pricing strategies in a time efficient manner. Their goal is to structure transfer pricing policies that are defensible, flexible, and congruent with your company's overall tax strategies, so that you can focus on other global business objectives.

Article about Transfer Pricing

• Five Questions on Transfer Pricing  
  Download (PDF-110 kb)
   
• ECJ Judgement on Cross-Border Transfer Pricing Adjustments
  Download (PDF-430 kb)
   
• BDO Transfer Pricing News February 2010
  Download (PDF-378 kb)
   
• BDO Transfer Pricing News October 2009
  Download (PDF-120 kb)
   

VAT often constitutes the first obstacle businesses have to overcome in the jurisdiction of a country they are going to enter for business purposes.  BDO can advise you on your first steps in developing your business abroad, by providing an overview of VAT obligations.

To ensure that the international needs of their clients with cross-border VAT issues are met, BDO Member Firms have established the VAT Centre of Excellence, which is responsible for monitoring and assisting BDO Member Firms in their area of expertise and for providing a technical resource that can be used on an international basis. Within this VAT Centre of Excellence VAT experts work closely together and exchange information and ideas on VAT.

Whether you are entering the European marketplace for the first time, or already control a large international orgasation, BDO VAT professionals can ensure that your VAT burden is minimised. At the same time, they can deal on your behalf with the fiscal authorities, settle disputes, and handle many other regulatory hurdles.

Article about VAT

• Central and Eastern European VAT Newsletter 2010/1
  Download (PDF-418 kb)
   
• VAT and sales taxes world wide 2008
  Download (PDF-510 kb)

• VAT and sales taxes world wide 2006
  Download (PDF-887 kb)
   
• Introduction to the 6th EU VAT Directive
  Download (PDF-1,702 kb)
   

The movement of individuals and businesses in an international context gives rise to complex taxation issues.  

Many expatriates are unaware of how exactly they can utilise their expatriate advantage to save on taxation carefully and effectively structure their finances to intensify their wealth building potential.
BDO Expatriate Services provide the solutions covering all the essential areas associated with effective offshore financial and taxation planning:

• We help the clients examine how changes in a person's residence and domicile can have an impact on their taxation liability, and how to make the most of any changes for the legal overall reduction of personal and gains taxation.
• We help the clients comply with the legislation and Revenue practice
• We can give an advice on tax strategies for individuals working overseas and provide tax services on the preparation and filing of tax returns.

We work closely with the Centres of Excellence and our associate firms around the world through the BDO Expatriate Services Committee which always discuss a pre-prepared expatriate case study in order to stimulate the sharing of ideas and to produce glabal expatriate Tax Planning Ideas and services.

Further information of our expatriate services can be obtained from BDO Contact.

Article about Expatriate Services

• BDO Expatriate News

A BDO "Tax Planning Idea" (TPI) is a toolkit of tax-saving or tax-deferment opportunities for companies and individuals involved in cross-border transactions. They are proprietary to BDO, evolving out of our experience in advising international growing businesses and their owners.

TPIs contain practical solutions to everyday problems - the simpler the better.

TPIs deal with saving tax in two countries on cross-border investment, the international relocation of executives, cross-boarder real estate transactions and estate planning, and in many other situations.

Applying a TPI could help you to:

• Save tax
• Save cash
• Reduce the reported tax charge in the accounts, thereby increasing earnings per share ('EPS')

A TPI can be useful in saving or deferring tax in any one of the following situations:

• Acquisition of a foreign business
• The sale of a foreign subsidiary
• Financing of international transactions
• Licensing intellectual property outside your home country
• A foreign (branch or subsidiary) loss
• The receipt of cross-border income
• International relocation of executives
• The purchase or sale of foreign real estate
• Cross-border estate planning.

BDO member firms understand the difficulties facing businesses an increasingly complex commercial and regulatory environment. Such businesses and their owners should focus primarily on profits, growth and cash flow, dealing with tax compliance and planning in an efficient manner.
BDO's TPI portfolio should be considered when a business has a liability to tax in more than one country.

• It should be borne in mind that coming up with a plan is only one aspect - implementing it is another.
• All businesses are different. Any TPI needs to be adapted in the light of a particular commercial fat pattern.
• It may sometimes be better, instead of starting with a TPI, to undertake a general review of your international structure - before coming up with a menu of ideas, some of which may be TPIs.
• TPIs are not easy to use. By their very nature they tend to be at the cutting edge of tax knowledge. They should only be implemented after a careful and thorough investigation.

If you are an existing client, or are already in contact with an adviser within the BDO organization, you should contact them in the first instance.
Otherwise, please visit the BDO International web site for your country's contact details, and ask for your local International Tax Coordiantor.

High Net Worth Individuals

Another part of BDO centres of excellence, a group of committees who are the professionals meet and discuss regularly on developing a comprehensive wealth management plan that includes both where to allocate the clients' assets and how to protect them against risks and liabilities.

Our tax experts are especially knowledgeable about changes in regulations that have the potential to benefit individuals and families with substantial assets and incomes.   BDO can help you plan your affairs to minimize your taxes, handle all the details of return preparation and ensure you're prepared should you be audited.

A particular concern of any high net worth individual or family is estate and trust planning. So you'll appreciate that we're expert in devising wealth transfer strategies and designing trust distribution systems.

The centre has developed an in-depth understanding of the unique needs of high-net-worth individuals and family offices and we have created comprehensive solutions that help you preserve wealth and enhance your investment performance. We provide effective and practical advice to efficiently manage your financial affairs.

BDO delivers integrated solutions for life and legacy on behalf of successful individuals and their families.

Corporate & Trustee Services

Corporate Trustee Services is one of the BDO expertise in the Centres of Excellence that serves the corporate and business market.  Our committees specialise in a diverse rage of public and private schemems including debt issues, fund management, superannuationation schemes, participatory schemes, custody and settlements.

The centre is experienced in complex default and bankruptcy proceedings, and can serve all aspects of the clients' succession or debt reorganization. We make sure the venture is set up properly, monitor ongoing operations, and work to prevent and resolve issues that could affect investors' interests.

We start by understanding your needs and goals, and working with you to develop the right solution for your business. We work alongside you to ensure we understand your business and the market issues. Instead of focusing on compliance and processes, we take a flexible, innovative and commercial approach.

BDO Corporate Trustee Services stands for integrity, honesty and reliability.  We take an active approach, providing sound advice and guidance to help ensure the success of the ventures we're involved with.   We have a wealth of experience you can draw on.

 Article about Tax Planning Ideas

• Six Questions on Tax Planning Ideas 
  Download (PDF-306 kb)