Received a Thai tax assessment? Start here
Identify the notice, receipt date, appeal deadline and accounting evidence, and separate an appeal from a request to defer payment.
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The short answer
In decision 632/2552, the Court held that the issuer of unauthorised tax invoices remained liable for the VAT shown as if registered. Improper cancellation did not remove liability on the facts of that case.
What happened
A business challenged VAT assessments for multiple periods. The issues included unauthorised invoices, sales to businesses in an export industrial zone, improper invoice cancellation and the time allowed for assessment.
The invoice holding
Applying section 86/13 paragraph two of the Revenue Code as addressed in the decision, the Court found liability for the VAT stated on the invoices. The zero-rating claim also depended on the prescribed conditions, not simply the customer’s location.
Why a ten-year assessment period applied here
The assessed facts brought the understatement above 25% of the base declared in the returns. The Court therefore applied section 88/6(1)(c) and the ten-year period addressed in that provision.
That conclusion depends on the facts and law considered in this decision. It does not set one period for all VAT situations or all taxes.
Practical document review
Trace each invoice from issue and delivery through cancellation and its treatment in tax records. A unilateral cancellation entry may not answer all the requirements that need checking.
- List each disputed invoice
- Keep originals and cancellation evidence
- Reconcile monthly reports and returns
- Check the law and practice for your actual tax period
Limits of this digest
This is a historical case digest, not a result achieved by the office or a statement that every cited provision remains unchanged. The decision also contains a fact-specific standing issue; it should not be used as general permission to bypass an appeal.
Common questions
Does cancelling an invoice settle the issue?
The cancellation process and tax treatment matter; the improper cancellation in this case did not remove liability.
Does this case make every assessment period ten years?
No. The Court applied the conditions established in that case.
Was this an office case?
No. It is a published decision summarised for education.
Sources and scope
Based on the decision text reviewed in the legal database. This is not an official court translation or commentary, nor an office case result.
General information, not advice for a specific matter. Your facts and applicable law may differ. Check the actual documents and deadlines before acting.