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Service guide
Tax Dispute & Appeals in Thailand.
How a tax dispute in Thailand runs: the 30 day appeal to the Commission of Appeal, the Central Tax Court, whether payment pauses, and what a tax lawyer does.
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Key facts
- How long do you have to appeal a tax assessment?
- 30 days from receiving the assessment to appeal to the Commission of Appeal, and 30 days from receiving the Commission's decision to appeal to the court, under the Revenue Code's appeal sections.
- Does appealing pause the tax payment?
- No. The Revenue Code states the appeal is not a deferral of tax payment. The tax stays payable within its time limit unless the Director-General grants permission to await the appeal's outcome.
- Which court hears tax disputes in Thailand?
- The Central Tax Court in Bangkok, a specialized court established by the Act for the Establishment of and Procedure for Tax Court B.E. 2528 (1985). It is currently Thailand's only tax court.
- Is a tax dispute the same as an audit?
- No. The audit is the investigation before the numbers are fixed; a dispute begins when you challenge the assessment the audit produced. Different stage, different work, and the audit file becomes the dispute's evidence.
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What a tax dispute in Thailand looks like
A tax dispute in Thailand starts when an assessment lands and you disagree with it. Everything before that point, the summonses, the meetings, the document requests, is the audit stage, and defending it is separate work covered under tax audit defense. Once the assessment official has fixed the numbers, the Revenue Code gives you a ladder to challenge them, and each rung has a deadline.
The ladder has two verified rungs. First, an appeal to the Commission of Appeal, filed in the form prescribed by the Director-General within 30 days of receiving the assessment. Second, if the Commission's written decision still goes against you, an appeal to the court within 30 days of receiving that decision. Tax cases are heard by the Central Tax Court, a specialized court established by statute in 1985.
Miss a 30-day window and the rung is gone. That is why the first thing tax lawyers in Thailand do with a new assessment is diary the deadline, before anyone debates the merits.
Warning: Appealing does not pause the tax bill
The Revenue Code is explicit: the appeal is not a deferral of tax payment. The assessed tax remains payable within its time limit unless the Director-General grants permission to await the appeal's outcome. A firm handles that permission request as part of the engagement, because losing it changes the cash position of the whole dispute.
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MSC International Law Office
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Law firmBangkokEnglish · Thai · Chinese (Mandarin) · Cantonese · Russian · German
International Legal and Cross-Border Business Advisory in Thailand and Asia
Law firmBangkokEnglish · Thai · Spanish
Experts assisting clients in conducting their businesses and protecting their rights and investments in Thailand across a wide range of legal matters.
The two verified rungs of the appeal ladder
Deadlines and decision-makers under the Revenue Code appeal sections (rd.go.th English text) and the Central Tax Court's establishing Act. Further appellate tiers exist within the courts of justice above the Central Tax Court.
| Commission of Appeal | Central Tax Court | |
|---|---|---|
| How you get there | Appeal in the form prescribed by the Director-General, within 30 days of receiving the assessment | Appeal against the Commission's decision, within 30 days of receiving it |
| Who decides | In Bangkok: the Director-General, a representative of the Office of the Attorney General, and a representative of the Ministry of Interior, or their representatives. In other provinces: the Provincial Governor, the Chief of the Regional Revenue Office, and the Provincial Attorney General, or their representatives | Judges of the Central Tax Court, the specialized tax court established by the Act of B.E. 2528 (1985) |
| Form of the outcome | A written decision of the Commission | A court judgment, itself open to further appeal within the courts of justice |
- How you get there
- Commission of Appeal: Appeal in the form prescribed by the Director-General, within 30 days of receiving the assessment
- Central Tax Court: Appeal against the Commission's decision, within 30 days of receiving it
- Who decides
- Commission of Appeal: In Bangkok: the Director-General, a representative of the Office of the Attorney General, and a representative of the Ministry of Interior, or their representatives. In other provinces: the Provincial Governor, the Chief of the Regional Revenue Office, and the Provincial Attorney General, or their representatives
- Central Tax Court: Judges of the Central Tax Court, the specialized tax court established by the Act of B.E. 2528 (1985)
- Form of the outcome
- Commission of Appeal: A written decision of the Commission
- Central Tax Court: A court judgment, itself open to further appeal within the courts of justice
What the lawyer does at each stage
At the Commission stage the work is written advocacy on the audit file. The lawyer drafts the appeal in the prescribed form, marshals the documents that support your position, and responds when officials use their power to summon evidence during the appeal, because failing to comply can forfeit the right to challenge the Commission's decision. Where a disputed assessment ties up money you say was overpaid, the same engagement often runs alongside tax refund claims.
At the court stage the dispute becomes litigation. The lawyer files within the 30-day window, pleads the case under the Tax Court's own procedural rules, and argues it before judges who hear tax cases full time. Firms that handle litigation and dispute work generally staff this stage together with the tax specialists who ran the Commission appeal.
Across both stages the honest job is triage: telling you which parts of the assessment are worth fighting, which are cheaper to concede, and what the written record from the audit will support. A lawyer can assess those odds; no one can promise the outcome.
How a tax dispute engagement runs
Diary the deadline, review the assessment
The firm confirms the date you received the assessment, calendars the 30-day appeal window, and reviews the assessment against the filings and the audit file to find the grounds worth pleading.
File the appeal to the Commission of Appeal
The appeal goes in on the Director-General's prescribed form within 30 days. The firm also advises on the tax bill itself, including whether to seek the Director-General's permission to await the outcome, since the appeal alone does not defer payment.
Argue the Commission stage
The firm answers any summons for evidence during the appeal and presses the written case. The stage ends with the Commission's written decision.
Take it to the Central Tax Court, or close
If the decision still goes against you and the numbers justify it, the firm files at the Central Tax Court within 30 days of receiving the decision. Otherwise the dispute closes and the firm handles payment, or any refund position, on the final figures.
When fighting an assessment is worth it
The economics are plain: the appeal costs professional fees and, unless deferral is granted, the tax is payable meanwhile. Fighting makes sense when the disputed amount is large against those costs, when the assessment rests on a position you can document, or when the finding would repeat in future years if left unchallenged. Conceding a small, weak point while appealing the substantial one is a common and sensible shape for these cases.
What you should not do is let the 30 days run while deciding. An appeal filed on time can be narrowed later; a missed deadline cannot be repaired. Firms quote for dispute work case by case, usually staged so you can stop after the Commission decision.
This page is general information, not legal advice. Rules, deadlines, and procedures change; for an assessment you have actually received, speak with a qualified professional before the appeal window closes.
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Common questions
Frequently asked questions
- How do I appeal a Revenue Department tax assessment in Thailand?
- The Revenue Code sets a two-rung ladder. You appeal first to the Commission of Appeal, in the form prescribed by the Director-General, within 30 days of receiving the assessment. If the Commission's written decision goes against you, you can appeal to the court within 30 days of receiving that decision. Tax cases are heard by the Central Tax Court in Bangkok. Missing either 30-day window closes that rung.
- Who sits on the Commission of Appeal?
- It depends on where the assessment official sits. For Bangkok, the Revenue Code's English text names the Director-General or his representative, a representative from the Office of the Attorney General, and a representative from the Ministry of Interior. In other provinces it is the Provincial Governor or his representative, the Chief of the Regional Revenue Office or his representative, and the Provincial Attorney General or his representative.
- Do I have to pay the assessed tax while the appeal runs?
- By default, yes. The Revenue Code states that the appeal is not a deferral of tax payment, so the assessed amount remains payable within its time limit while the appeal proceeds. The exception is permission from the Director-General to await the outcome of the appeal, which a firm typically requests as part of the engagement.
- What is the Central Tax Court?
- Thailand's specialized court for tax cases, established under the Act for the Establishment of and Procedure for Tax Court B.E. 2528 (1985) and currently the country's only tax court, sitting in Bangkok. It hears disputes across taxes including income tax, customs duties, excise, and land and building tax, under its own procedural rules, and its judgments can be taken further within the appellate tiers of the courts of justice.
- Can I lose the right to appeal?
- Yes, in two verified ways. Filing outside the 30-day window closes the rung you missed. And during a Commission appeal, officials may summon evidence; the Revenue Code provides that an appellant who does not comply is not entitled to appeal against the Commission of Appeal's decision. Keeping every response inside its deadline is a core part of what the lawyer manages.
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Law firmBangkokEnglish · Thai · German
YOUR ONE-STOP COORDINATOR FOR INTEGRATED LEGAL, TAX AND BUSINESS SOLUTIONS
MSC International Law Office
Free consultation · 30 min
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Experts assisting clients in conducting their businesses and protecting their rights and investments in Thailand across a wide range of legal matters.
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