Nopporn Charoenkitraj

His specialties include:

• tax advice for shareholding and corporate restructuring and mergers and acquisitions;
• advice on digital taxes, including digital service tax, as well as complex transactions planning related to digital assets;
• EPC contractual tax planning structure and documentation;
• advice on tax planning structure for VC, fund raising and capital market; 
• taxation of inbound and outbound investments;
• wealth management for high net-worth individuals and family businesses, related tax planning, corporate reorganization, and gift, inheritance, and property tax;
• taxation of banking businesses and financial instruments;
• tax planning for real estate development projects;
• general tax advice, such as that pertaining to supply chain management, double taxation treaties, and joint ventures; 
• tax advice on working nomads, secondment arrangement, and employee compensation and benefits; and
• tax audits, tax settlement, tax dispute resolution, tax appeal, and tax litigation.

Restructuring and M&A Planning

• Assisted the client by providing a Thai tax opinion on the application of relevant Double Tax Agreements for capital gains tax exemption. The jurisdictions involved include Hong Kong, Australia, and India. Specifically, with respect to the Thailand–India Double Tax Agreement, we provide an in-depth analysis of Article 13 concerning the allocation of taxing rights on capital gains arising from the sale of shares in an Indian target.
• Assisted is a leading agribusiness company in providing strategic legal counsel on complex cross-border tax matters, ensuring transactions were structured in full compliance with applicable tax regulations across multiple jurisdictions while maximising tax efficiency.
• Advised a leading Thai real estate developer on its second branded residence project in Kamala, Phuket. This transaction involved a branded residence management agreement with Hotels Group, marking a significant milestone expansion in the luxury residential sector. We assisted the client with strategic tax structuring, as well as advising the client until the closing of the transaction. The team previously represented the company in their first branded residence project in Hua Hin and is proud to support the company’s continued growth and strategic partnerships in the hospitality and real estate sectors.

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 for 0 percent VAT.
• Representing a world-leading telecom cable manufacturer in tax litigation concerning corporate income tax and VAT on sale transactions with a 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.

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• Band 3, Individual Award (Tax), Chambers Asia Pacific, 2022-2026
• Leading Partner, The Legal 500 Asia Pacific, 2025-2026
• Notable Practitioner (General corporate tax), ITR World Tax 2025-2026
• Commended External Counsel for 2025, In-House Community Counsel of the Year Awards 2025

• In 2023, Nopporn provided pro bono legal counsel to a well-known humanitarian organization on obtaining charitable organization status in Thailand. This includes guidance on existing regulations, liaising with the revenue department, preparing correspondence to the Ministry of Finance, and exploring alternative avenues for achieving the project objective.
• In 2021, Nopporn co-led a team of lawyers in the Bangkok Office in a tax and legacy law project in partnership with the United Nations Refugee Agency.