Update on electronic tax filing and documentation in Thailand

Since 2012, the Revenue Department (“RD”) has had a policy of supporting the preparation and delivery of electronic tax invoices (“e-tax invoices”) or electronic receipts (“e-receipts”) to support electronic transactions in the private sector and to increase the efficiency of electronic services (“e-services”) of the government.

Keywords: Mazars, Thailand, Tax, VAT, Revenue Department, Digital Signature, Revenue Code, e-Tax Invoices, Certification Authority

28 October 2019

The RD has issued regulations on the preparation, delivery, and storage of e-tax invoices and e-receipts. Under these regulations, there are two methods for preparing e-tax invoices and e-receipts:

1. Preparing e-tax invoices and e-receipts with a digital signature

This method requires the user to create a system (software) meeting all requirements regarding e-tax invoices and e-receipts, especially regarding the certified digital signature.

Rules, procedures, and conditions of this method are specified in the RD regulations announced on 19 June 2017 and 30 April 2018.

2. Preparing e-tax invoices by email

This method is designed for small enterprises with an assessable income not higher than 30 million baht during each accounting period.

Rules, procedures, and conditions of this method are specified in the RD regulation announced on 1 March 2017.

Digital signature

E-tax invoices and e-receipts are issued with a digital signature and an XML file containing the VAT data submitted to the RD. Documents which can be prepared in electronic form with a digital signature include the following:

  • A full tax invoice under Section 86/4 of the Revenue Code;
  • A summary tax invoice under Section 86/6 of the Revenue Code;
  • A debit note under Section 86/9 of the Revenue Code;
  • A credit note under Section 86/10 of the Revenue Code; and
  • A receipt under Section 105 bis of the Revenue Code

Advantages

1. Reduces redundancy and operational procedures.

2. Saves time and money related to delivering documents.

3. Allows a business to use the information for further processing immediately.

4. Saves space and document storage costs.

5. Is convenient and reduces the time needed to search for documents.

Disadvantages

1. Businesses with a limited IT infrastructure and/or a simple accounting system must make an initial investment. However, the RD allows an additional deduction of expenses paid by corporate income taxpayers for investments related to an electronic tax system.

2. The technology required to prepare and transmit the electronic data is still being refined and is not yet accessible for mass adoption.

3. If e-tax invoices have already been delivered and mistakes are found, they cannot be revised. Businesses must cancel the old ones, issue new ones, and send them out again.

4. Businesses are still required to prepare output VAT reports for e-tax invoices.

Email

Documents which can be prepared in electronic form by email system include the following:

  •  A full tax invoice under Section 86/4 of the Revenue Code;
  • A debit note under Section 86/9 of the Revenue Code; and
  • A credit note under Section 86/10 of the Revenue Code

Advantages

1. Saves time and money related to delivering documents.

2. Is convenient and reduces the time needed to search for documents.

3. Does not require an electronic certificate and digital signature.

Disadvantages

1. If e-tax invoices have already been delivered and mistakes are found, they cannot be revised. Businesses must cancel the old ones, issue new ones, and send them out again.

2. Businesses are still required to prepare output VAT reports for e-tax invoices.

Summary

E-tax invoice and e-receipt with digital signature

E-tax invoice by email system

 1. No limitation on income

 1. Income not exceeding 30 million baht per year

 2. For tax invoices (full and summary), debit notes, credit notes, and receipts

 2. For tax invoices (full), debit notes, and credit notes

 3. Data prepared in XML or another format

 3. Data prepared in PDF/A3 form only

 4. Uses electronic certificate and digital signature

 4. Uses email time stamp

 5. Data delivered to the RD in a specified format

 5. Data kept in a database

Currently, businesses can apply voluntarily for the e-tax invoice and e-receipt system. It is not yet compulsory.

Process – preparing e-tax invoices and e-receipts with digital signature

Businesses who wish to prepare e-tax invoices or e-receipts under this method must obtain approval from the RD by submitting an application (Form Bor.Or. 01) through the RD’s website and procure an electronic certificate – the Certification Authority (“CA”).

When e-tax invoices and e-receipts are prepared, they must be delivered as follows:

1. Delivered to the purchaser of goods or services by one of the following methods:

a) in the form of electronic data as agreed on, such as by email; or

b) in the form of a hard copy at the request of the purchaser of the goods or services, where the hard copy must contain the statement, “This document has been prepared and sent to the Revenue Department electronically”.

2. Delivered to the RD:

  • The data shall be delivered to the RD by the fifteenth day of the month following that month in which e-tax invoices and e-receipts are issued.
  • Businesses can choose one of the following delivery channels:

(i) Host-to-host

This enables business with very large volumes of transactions to transfer the data directly to the RD.

(ii) Service provider

This is the delivery of data through an agent that has been approved by the RD. The service provider can also assist the business in preparing the e-tax invoices and e-receipts. Businesses can use this channel without investing in the software and hardware.

(iii) Uploading files

Upload the data to the RD website. Suitable for small businesses with a low volume of transactions.

Process – preparing e-tax invoices by email

Businesses who want to issue and deliver e-tax invoices by email can submit an application form (Form Kor.Or. 01) to the RD.

Applicants must meet the following criteria to be eligible to prepare, deliver, and keep e-tax invoices by email:

1. Must be an individual with assessable income not exceeding 30 million baht per tax year from 2015 onwards, or a company or partnership having an income not exceeding 30 million baht per accounting period from the accounting period beginning on or after 1 January 2015 and onwards.

2. Must not be a VAT registrant that has already received, or has requested to receive, approval to prepare e-tax invoices and e-receipts with a digital signature.

3. Must not have evaded taxes and have no history of issuing or using counterfeit tax invoices or tax invoices that were illegally issued.

Once a business has obtained approval from the RD, it must prepare an e-tax invoice in PDF/A3 form. The e-tax invoice can then be sent to the email address of the purchaser of goods or recipient of services, and a copy sent to RD for the time stamp.

Tax incentives

To encourage businesses to develop an electronic tax payment and electronic tax return submission system, corporate income taxpayers are eligible to claim a double deduction on certain expenses paid during 30 April 2019 – 31 December 2019.

For more information, please read tax deduction on e-tax system investments

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