A private letter ruling is a non-binding ruling issued by the Thailand Revenue Department answering specific written questions posed by a taxpayer.

Non-binding means that a private letter ruling is only persuasive in nature and thus does not have to be followed by the Revenue Department during a subsequent tax audit.

A private letter ruling is submitted to the regional Revenue Department office where the taxpayer's business is located. 

There is no specific time period in which the Revenue Department has to answer a private letter ruling request, but usually they are answered within 3 to 6 months or less.  

We recommend taxpayers to submit a private letter ruling request to the Revenue Department in cases of novel tax questions or for large transactions in which the tax implications are in question or dispute.

The Revenue Department publishes some private letter rulings on various topics which can be researched and used to help determine tax positions on specific important or large transactions.

Our private letter ruling service includes the following:

  • Review intended transactions and documents.
  • Provide advice on tax implications.
  • Provide recommendations to reduce tax exposure.
  • Prepare supporting documents.
  • Draft private letter ruling in English and Thai.
  • Assist with submission of the private letter ruling to the regional Revenue Department office.
  • Follow up with Revenue Department until issuance of answer to the private letter ruling request.
  • Correspondence by email, telephone and in person meetings when necessary.