Legal service for foreign clients
Administrative & Tax Court Litigation in Thailand
When an official order or a tax assessment is wrong, the law still gives you a route.
Quick answer
Administrative orders — a refused licence renewal, a demolition order, an administrative fine — can be challenged for revocation at the Administrative Court, normally after an internal appeal and within 90 days of learning of the ground. A tax assessment must be appealed to the Appeal Commission within 30 days of the notice, then filed at the Central Tax Court inside a further 30-day window from the ruling. The clocks are short, so reviewing documents fast matters more than waiting to negotiate.
From THB 50,000 — From 50k per court level · high-value assessments priced proportionally · Tax appeal 6–12 months · Central Tax Court 10–20 months · Administrative Court 1–3 years
Who this is for
- Businesses hit with back-tax assessments plus surcharge and penalty
- Operators refused a renewal or stripped of a licence
- Building owners served with demolition or stop-work orders
- Bidders on state contracts who consider the selection unlawful
- Anyone whose application a state agency left unattended beyond a reasonable time
What you receive
- Mapping every appeal and filing deadline, with the final safe date stated in writing
- The internal appeal or the tax Appeal Commission submission
- The claim to the Administrative Court or Central Tax Court with a structured exhibit bundle
- An application to stay the order's effect during proceedings
- Recomputation of the tax burden by our accounting team, usable as evidence
- Post-case practice notes so the same issue is not assessed again
Documents to prepare
- The assessment notice or administrative order as received
- The envelope or delivery proof establishing when the clock started
- Accounts, tax invoices, and contracts relating to the assessed issue
- Correspondence with officials and notes of every meeting
- The existing licence and its annexed conditions in licensing cases
How it works
5-step process
- 1
Fix the receipt date first
All deadlines run from receipt, not from the date printed on the notice.
- 2
Separate law from fact
Legal issues turn on interpretation; factual ones turn on documents and numbers.
- 3
Exhaust the administrative appeal
Skipping it can bar the claim, so file properly and keep the filing proof.
- 4
File suit and seek a stay
A stay avoids paying or demolishing before the case ends.
- 5
Hearings and judgment
Bring accounting or engineering experts when the issue is technical.
In depth
Administrative & Tax Court Litigation: what foreign clients need to know
Disputes with state agencies and the Revenue Department follow a path unlike ordinary civil litigation. What kills these matters is the clock: many rights of objection expire once the statutory period from the date of the notice runs out, however strong the argument on the merits. Our work therefore begins by confirming the date of receipt and counting the calendar backwards.
The internal appeal stage that must come before court
For a tax assessment, the taxpayer must appeal to the appeal commission within the period running from receipt of the assessment notice. Skipping straight to court risks dismissal because the statutory pre-condition has not been exhausted.
That internal stage is not a formality to be waved through; it is the last easy chance to put fresh evidence on file. We therefore build the appeal with the law, the facts and a reconciliation table an officer can follow line by line.
Filing at the Central Tax Court and posting security
When the appeal decision goes against you, the next step is a claim to revoke the assessment at the Central Tax Court, within the window running from receipt of that decision. A parallel decision is whether to seek suspension of payment during the case, since surcharges keep accruing while it runs.
Suspension usually requires security, whether a bank guarantee or pledged assets. The cost of that security must be weighed against the surcharge accruing if you instead pay first and reclaim later. We model both paths in figures before you choose.
Administrative cases when a state order affects your rights
The administrative orders businesses meet most often are refusals to renew a licence, revocation of a right, suspension orders, and unfair procurement outcomes. The path is to exhaust the internal appeal, then file at the Administrative Court within the prescribed period.
What decides administrative cases is often not the substance of the decision but the procedure the agency used: the chance to be heard, the reasons given for the order, and whether discretion met the proportionality standard. We therefore preserve every communication with the agency from day one.
Cost structure: government fees vs professional fees
| Item | Official fee | Professional fee | Note |
|---|---|---|---|
| Reviewing the notice and assessing prospects | No government fee | THB 15,000–35,000 | Do it as soon as the notice arrives; the finding decides whether to fight or negotiate |
| Preparing and filing the appeal to the commission | No filing fee at this stage | THB 60,000–180,000 by number of issues and tax years | Includes the reconciliation schedules and attending clarification meetings |
| Litigating at the Central Tax Court or Administrative Court | Court fees scale with the amount in dispute up to the statutory cap | From THB 200,000 by complexity and number of hearing days | Security for a suspension request is a separate item paid directly to the financial institution |
An exporter assessed retroactively over an incomplete document set
Situation: Officials rejected the rate the exporter had applied because the proof of shipment out of the country was incomplete.
What we did: We recovered a second evidence set from the carrier and the bank, then matched each invoice to its export entry and payment receipt, item by item.
Outcome: The commission cut the assessment substantially at the appeal stage, with no court filing needed.
An operator refused a renewal without stated reasons
Situation: The agency issued a one-line refusal that identified neither the facts nor the legal basis relied on.
What we did: We exercised the right to reasons and to the case file, then framed the challenge primarily on procedural grounds.
Outcome: The agency reconsidered and reopened the file for fresh submissions, letting the business keep operating.
When to act, and when waiting is fine
Start on the day the assessment notice or order arrives
Fix the deadline before anything else; a right that has lapsed cannot be revived by the strength of your argument.
No need to sue yet if the issue is a numerical discrepancy fixable with documents
Here, closing it out at the audit stage is far cheaper and leaves no litigation record attached to the business.
FAQ
Frequently asked questions
Must the tax be paid before appealing?
Not immediately if the appeal is timely, but the surcharge keeps running, so consider whether partial payment is cheaper.
The 30 days lapsed — anything left?
Options narrow sharply; force majeure grounds or an internal review request may remain, assessed case by case.
Is counsel required in administrative cases?
Not mandatory, but the process is document-heavy and inquisitorial, so framing the issues well matters greatly.
Will officials retaliate after a suit?
We keep everything in writing with a full contact record, which is the strongest protection available.
Does winning bring damages?
Damages can be claimed in administrative cases on proof of loss from unlawful action; tax cases usually yield a refund with statutory interest.
What does the accounting team add in tax cases?
They rebuild working papers against the allegations and compute the correct liability as evidence.
Do we have to pay first and sue afterwards?
Not always. Payment can be suspended during the case, but security in the amount set by the court or agency is usually required.
Can surcharges and penalties be reduced?
Reduction is available in many cases where you show no intent to evade and full cooperation throughout the audit.
How long does a Central Tax Court case take?
First instance commonly runs about one to two and a half years, depending on the issues and documentary evidence to be examined.
Must an administrative case always go through the internal appeal first?
In nearly every case the internal remedy must be exhausted first, unless the specific statute allows direct filing.
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Written by: Thai Law & Accounting Services — attorneys and licensed accountants
Reviewed by: Reviewed by a Notarial Services Attorney registered with the Lawyers Council of Thailand.
Last updated: 2026-08
Information as of August 2026. Government fees and processing times change — verify with the relevant agency before acting, or let our team verify for you.