Nopporn Charoenkitraj

Nopporn Charoenkitraj

Partner
Baker & McKenzie Limited Attorneys at Law

Biography

Nopporn joined Baker McKenzie in 2007 after practicing tax law with another law firm in Bangkok for seven years. He became a Partner in 2016 and is currently active in the Tax Practice Group.

Practice Focus

With his combined 22 years of practice, Nopporn provides comprehensive legal advice on tax law and other aspects of civil and commercial law, advises on tax structure for M&A, digital and technology transactions, inbound and outbound investments, and wealth management, assists in implementing corporate and shareholding restructuring, and represents clients in a tax dispute and litigation.

Representative Legal Matters

Restructuring and M&A Planning

  • Advised JWD InfoLogistics Public Company Limited (JWD), one of the largest logistics companies listed on the Stock Exchange of Thailand, on its merger transaction with SCG Logistics Management Co., Ltd.  (SCGL), a subsidiary of Siam Cement Public Company Limited’s (SCC), by way of share swap, and private placement, with a transaction value of THB 19 billion. This merger would provide further opportunities for future synergies enabling exponential growth of merged company which will become the largest integrated logistics and supply chain solutions provider in ASEAN upon the completion of the merger transaction. We assisted the client with guidance on all the complicated tax planning and issues during the structuring and implementation phases, as well as advising the client until the completion and closing of the transaction.
  • Assisting one of the world's leading reinsurers, in acquiring a Thai insurance company through a tax-efficient structure and developing a post-acquisition holding structure.
  • Assisting the world’s largest global manufacturer and supplier of glass products with M&A transactions involving three of its subsidiaries, both in Thailand and in Vietnam, the delisting of Vinythai Public Company Limited from the Stock Exchange of Thailand, and amalgamation to form the largest chlor-alkali chemicals business in Southeast Asia.

Tax Planning

  • Representing a technology company in meetings with the Thai tax authority regarding the development of an extraterritorial VAT draft bill, and advising the company on tax implications regarding business operations in Thailand on topics ranging from methods of payment-to-payment models for gift cards to insurance programs.

Litigation

  • Representing a Thai airline in complex property tax litigation involving a property fund.
  • Representing a film production house in a tax appeal case concerning eligibility to zero percent VAT.
  • Representing a world-leading telecoms cable manufacturer in tax litigation concerning CIT and VAT on sale transaction with the Thai state enterprise.

Fintech

  • Assisting a global social media conglomerate from with tax issues pertaining to blockchain-based payment and cryptocurrency, including facilitating a discussion with the Revenue Department.
  • Advising a major tech company on the tax implications of digital payments related to gift cards, digital payment models, service programs, transaction structures, and day-to-day operations.
  • Providing advice on the international and domestic tax implications of the issuance and transfer of utility and investment tokens.

Professional Honors

  • Band 3, Individual Award in Tax, Chambers Asia Pacific, 2022-2023

Admissions

  • Thailand (2007)

Education

  • University of Florida (LL.M. in International Taxation) (2012)
  • Thammasat University (LL.B.) (2000)

Languages

  • English
  • Thai

Presentations

  • Guest speaker for two-day sessions, "CRS Insights," UOB Private Banking and its wealth clients seminar, 16 and 17 May 2023
  • Co-speaker, "Tax Essentials and Transfer Pricing," BTS Group Holdings and its affiliated companies seminar, 8 May 2023
  • Co-speaker, “Build Trust, Harvest Legacy,” Baker McKenzie client exclusive seminar, 24 April 2023
  • Guest speaker, "CCC amendment and merger," the Japanese Chamber of Commerce for JCC's tax committee seminar, 21 April 2023
  • Guest speaker, "Sustainable wealth transfer: inheritance tax and investment outlook in 2023," Krungthai Bank seminar, 31 March 2023