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VAT Reverse Charge on Non-Resident Service Provider
Thai Service Recipient v Revenue Department
Composite summary — not a single reported case. This entry distils a settled line of Thai Supreme Court (Dika / ฎีกา) authority for legal education. It is not a transcript of one reported judgment, and the heading is not a citable case number. Do not cite it as specific case law — consult a Thai-qualified lawyer for the authoritative Dika number and current application.
Facts
Thai recipient of non-resident services failed to self-account VAT under reverse-charge rules; Revenue Department imposed surcharge.
Legal Issue
Application of Revenue Code §83/6 reverse-charge to digital services from non-resident providers.
Holding
Supreme Court has consistently upheld Revenue Department reverse-charge enforcement where the service is used / benefited in Thailand.
Reasoning
Revenue Code §83/6 captures place-of-supply test; OECD digital-VAT principles aligned.
Significance
Thai consumers of foreign digital services may bear self-account obligations.
Practical Takeaway
Identify reverse-charge triggers (cloud, SaaS, royalties, services) and file PP.36; foreign suppliers may register voluntarily under the digital-platform regime.
Cited Statutes
- Revenue Code §83/6
This entry summarises a representative line of authority from the Thai Supreme Court (ฎีกา). It is intended for general legal education only and is not a substitute for advice from a Thai-qualified lawyer. Individual Dika case numbers are being verified against primary sources; until then these entries are presented as composite doctrinal summaries.
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