Contact Details
T: + 66 2 264 8000
F: + 66 2 657 2222
Email:  |
Amnart Khongsakda is a senior associate in the Tax Practice Group at Weerawong, Chinnavat & Partners Ltd. He advises on complex Thai and cross-border tax matters, with a focus on transaction structuring, double tax treaty application and tax controversy. His work covers high-value inbound investments, cross-border financing and multinational operating structures. He also assists clients in Revenue Department audits, helping them substantiate tax positions and manage dispute risk.
His practice includes advising on permanent establishment exposure, the characterization of cross-border payments, withholding tax and VAT implications, and the allocation of tax risk within contractual frameworks. Amnart works closely with the firm’s M&A, capital markets, banking and finance, foreign direct investment, and restructuring teams on transaction and audit-related tax matters, from structuring and documentation to implementation and tax audit response.
Recent Experience
- Advised on the tax and structuring implications of a multinational conference organizer’s operations in Thailand, including the interplay between Foreign Business License (FBL) requirements and permanent establishment exposure, covering service characterization, cross-border revenue structures, profit attribution and corporate income tax risk under the Thailand–UK Double Tax Agreement.
- Advised on the Thai tax structuring of a hyperscale data center project in Thailand with an aggregate investment value of approximately USD 2.2 billion.
- Advised Wyss Academy for Nature, a European foundation, on cross-border tax structuring and permanent establishment risk under the Thailand–Switzerland Double Tax Agreement in connection with activities conducted in Thailand.
- Led the tax analysis and preparation of a comprehensive Thai tax memorandum for Éolica Navarra, SLU, a Spanish renewable energy investor, covering corporate income tax structuring, VAT, withholding tax exposure, expatriate personal income tax, local taxes, treaty interpretation under the Thailand–Spain Double Tax Agreement, and Pillar Two global minimum tax implications.
- Advised Changan Automobile on tax structuring and transaction-related tax risks, including VAT treatment, withholding tax exposure and contractual tax risk allocation, in connection with the construction of a new manufacturing facility in Thailand with an investment value exceeding THB 10 billion, representing the client’s first overseas production investment outside its home jurisdiction.
- Advised United Foods Public Company Limited on the structuring of royalty arrangements and the application of the Thailand–UK Double Tax Agreement, including VAT and withholding tax considerations.
- Advised on cross-border tax and contractual structuring for an international entertainment and artist management structure involving Thailand, Singapore and Korea, including intercompany service arrangements, withholding tax, VAT, transfer pricing and territorial allocation of commercial rights.
- Advised on Thai corporate income tax implications of debt restructuring and debt release under a court-approved business rehabilitation plan involving aggregate indebtedness of tens of billions of baht, including the availability of tax exemption for income arising from debt discharge and timing of income recognition.
- Advised on Thai corporate income tax implications of bad debt write-offs involving receivables owed by an insolvent overseas debtor, with exposure amounting to several hundred million baht, including deductibility under Thai bad debt write-off rules, supporting documentation on foreign insolvency proceedings and timing of deduction.
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EducationLL.M International Economic Law-Mention bien (Honours), The European School of Law, Toulouse 1 University Capitole, France, 2020
LL.B. Business Law (Honours), Chulalongkorn University, 2013 Bar AdmissionsAttorney At Law, Lawyers Council of Thailand, admitted 2014
Notarial Services Attorney, admitted 2020
Registered with the Department of Business Development under Thailand's Ministry of Commerce, authorized to certify signatures in accordance w CitizenshipThai LanguagesThai, English |
