Nitikan Ramanat

Nitikan Ramanat

Partner
Baker & McKenzie Limited Attorneys at Law

Biography

Nitikan Ramanat is a partner in the Tax Practice Group at Baker McKenzie, Bangkok Office. With over 15 years of experience, he has worked in the Tax Practice Group and previously in the Capital Markets and Corporate & Commercial Practice Groups. His practice focuses on tax and wealth management.

Apart from his role at Baker McKenzie, Nitikan serves as a responsible instructor and course coordinator for the Wealth Management Law course in the Bachelor of Laws Program in Business Law (International Program) at Faculty of Law, Thammasat University. He is also a guest lecturer on tax, wealth management, and family business topics at various reputable universities and a speaker at numerous public and private events.

Practice Focus

Nitikan's extensive experience includes handling complex shareholding restructuring, investment and business structuring, tax on cross-boarder transactions, and wealth management tax and legal matters, including multi-jurisdictional succession planning, wills, prenuptial agreements, and offshore trusts.

Nitikan advises a broad range of clients, including multinational companies, Thai listed and non-listed companies, insurance companies, insurance brokerage firms, private banks, other financial institutions, and high-net-worth families and individuals on tax and legal matters.

Representative Legal Matters

Wealth Management and Family Business Governance

  • Assisted Ultra-High Net Worth (UHNW) families and individuals with multi-jurisdictional succession planning and the transfer of wealth and family businesses to future generations.
  • Advised UHNW families and individuals on gift tax and inheritance tax strategies, established family holding companies, and facilitated the setup of offshore trusts.
  • Assisted UHNW families and individuals on family business governance by drafting family business legal documents, such as a family constitution, articles of association of family holding companies, family shareholder agreements, family asset holding agreements, family asset allocation agreements, prenuptial agreements, and wills.
  • Assisted UHNW families and individuals in restructuring the shareholding of companies controlled by family members, both listed and non-listed on the Stock Exchange of Thailand (SET). This included seeking waivers for tender offers for all of the business from the Securities and Exchange Commission, and reporting and disclosing information about shareholding restructuring in accordance with securities laws.
  • Assisted UHNW families and individuals in filing and paying for gift tax and inheritance tax returns, and provided assistance in case of tax audits.
  • Provided legal and tax advice on charitable activities through trusts, foundations abroad, and other types of charitable entities or organizations.

Tax Advice

  • Advised on mergers and acquisitions, entire business transfers, partial business transfers, assets acquisitions and disposals, business restructuring, real estate development projects, and foreign investments, as well as the relevant tax matters involved in the implementation of these transactions.
  • Advised on tax matters related to licensing and broadcasting international sports content in Thailand.
  • Advised on investments and business operations in Thailand, including tax benefits such as structuring shareholding for investment in Thailand, BOI tax privileges, obtaining approval from the International Business Center (IBC), etc.
  • Advised on Common Reporting Standards (CRS) and compliance.
  • Advised on tax issues related to foreign investments and appropriate structures for foreign investments.
  • Provided legal advice on tax law compliance, discussions with the Revenue Department on tax-related issues and tax audits.
  • Advised on tax matters in share purchase agreements, property purchase agreements, and other commercial agreements.

Professional Associations and Memberships

  • The Society of Trust and Estate Practitioners (STEP)
  • Thai Bar Association,  Extraordinary member
  • Law Society of Thailand

Admissions

  • Thailand (2007)

Education

  • Wealth Management Institution, Singapore (Certificate in International Tax Consideration for Families of Wealth) (2023)
  • University of Pennsylvania (LLM) (2014)
  • International Tax Center Leiden (Summer Course in International Tax Law) (2014)
  • China University of Political Science & Law (Certificate of Chinese Law Study) (2013)
  • Tulane University (Certificate of Chinese Law Study) (2013)
  • Central Tax Court (Certificates of Taxation Law and Tax Accounting and Tax Litigation) (2010)
  • Thammasat University (LLB, second-class honors) (2007)
  • Lawyers Council of Thailand (Certificate of Advocacy Training) (2007)

Languages

  • English
  • Thai

Previous Offices

  • Taipei
  • Panelist, "Worldwide Taxation: Which Direction Should Thailand Take?," Thammasat University, November 2024
  • Speaker, "2024 Asia Pacific Wealth Management Symposium," Baker McKenzie, April 2024
  • Speaker, “Build Trust, Harvest Legacy,” Baker McKenzie, April 2023
  • Co-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 Client Alert, November 2023
  • Co-author, "Offshore-sourced income brought into Thailand from 1 January 2024 onward will be subject to Thai personal income tax," Baker McKenzie Client Alert, September 2023
  • Co-author, "Thailand: Recent Tax Developments," Bloomberg Tax, 20 July 2021