Sirirasi Gobpradit

Sirirasi Gobpradit

Partner
Baker & McKenzie Limited Attorneys at Law

Biography

Sirirasi joined Baker McKenzie in 2013 and is a partner in the Tax Practice Group of Bangkok office. Sirirasi is a visiting lecturer for taxation classes at the Faculty of Law and the Faculty of Commerce and Accountancy of a leading university in Thailand. Sirirasi was ranked as a Rising Star in Tax by The Legal 500 Asia Pacific in 2023 and 2024 and was awarded as Indirect Tax Rising Star by International Tax Review (ITR) Asia Pacific Tax Awards 2024.

Practice Focus

Sirirasi has considerable experience in providing tax advice for M&A and corporate restructuring, conducting health check from a tax perspective, providing tax advice for employment benefits (including equity-based compensation programs), providing tax advice for cross-border transactions, and advising on general tax planning.

Sirirasi regularly assists and represents clients at all stages of tax disputes, including tax audit process, appeal process, and court proceedings.

Representative Legal Matters

  • Assisted a German multinational reinsurance company, which is one of the world's leading reinsurers, in acquiring the Thai target insurance company through the most tax-efficient acquisition structure. Provided tax advice on all phases of the transactions and assisted with the implementation of the post-acquisition holding structure until completion.

  • Assisted the world’s largest global manufacturer and supplier of glass products to explore tax-efficient structures for M&A transactions involving three of its subsidiaries both in Thailand and in Vietnam, the delisting of Thai company from the Stock Exchange of Thailand and the amalgamation to form a new company.

  • Advised various multinational companies on Thai tax considerations for the Employee Stock Ownership Plan (ESOP) scheme, such as the recharge mechanism and the mandatory sale of vested shares immediately after the acquisition.

  • Provided tax advice and recommendation on the permanent establishment (PE) issue arising from the cross-border secondment arrangement adopted by various multinational companies. Assisted the clients with the implementation of the recommended solution.

  • Represented a Japanese-based client in handling tax audit and tax appeal case encompassing the classification of income under the double tax treaty between Thailand and Japan. Assisted with the tax ruling request and the settlement of international tax dispute by Mutual Agreement Procedure (MAP) between the Government of Thailand and the Government of Japan.

Professional Honors

  • Indirect Tax Rising Star, International Tax Review (ITR), 2024
  • Rising Star in Tax, The Legal 500 Asia Pacific, 2023-2024

Professional Associations and Memberships

  • The Thai Barrister at Law
  • The Lawyers Council of Thailand
  • Notarial Services Attorney
  • Federation of Accounting Professions
  • The British Chamber of Commerce Thailand Legal & Taxation Group

Admissions

  • Thailand (2007)

Education

  • Sukhothai Thammathirat Open University (Bachelor of Accounting) (2016)
  • University College London (LLM, International Banking and Finance Law) (2012)
  • King's College London (LLM, Tax Law) (2011)
  • Chulalongkorn University (LLB, Business Law) (2007)

Languages

  • English
  • Thai

Speaker, "Mastering Tax & ESG: Essential Skills for Legal Experts," Law Chula Alumni Association, June 2024

Author, Thailand chapter of "The Inward Investment and International Taxation Review — 14th Edition," Lexology In-Depth, April 2024

Author, "Global Private M&A Guide 2024," Baker McKenzie, February 2024

Author, "Offshore-sourced income received before 1 January 2024 can be brought into Thailand in 2024 or later without being subject to Thai personal income tax," Baker McKenzie, November 2023

Author, "Offshore-sourced income brought into Thailand from 1 January 2024 onward will be subject to Thai personal income tax," Baker McKenzie, September 2023

Author, "New tax exemptions for investment tokens = opportunities for tokenization in Thailand," Baker McKenzie, March 2023