| Popis: |
In Thailand, the fairness of the process used to resolve tax disputes between Thai taxpayers and the Revenue Department of Thailand has not been extensively and systematically examined. The purpose of this thesis is to examine the fairness of the tax dispute resolution process in Thailand. Analysis of the process in this thesis covers dispute resolution procedures at both the administrative and judicial levels. The thesis provides suggestions that could help Thailand to develop a fairer tax dispute resolution process. The thesis systematically analyses the fairness of the Thai tax dispute resolution process using theories of justice, particularly procedural justice, as a theoretical framework for the analysis. To provide greater analysis of the process and develop suggestions for Thailand, the thesis employs a mixed method approach to research, using a combination of legal research and qualitative research approaches. The legal research includes investigation of the Thai and Australian tax dispute resolution systems and a comparison of the two systems, in seeking good practices and learning lessons from the Australian experience. The qualitative research involves interviews with key stakeholders who are knowledgeable about and practised in the Thai tax dispute resolution system. The thesis indicates that the current tax dispute resolution system in Thailand is deficient in providing a fair process for taxpayers. Serious problematic aspects of the system arise in the tax dispute resolution process at the administrative level. Some deficiencies are also found in the process at the judicial level. The Australian tax dispute resolution process, at both the administrative and judicial levels, is characterised by a number of good practices which offer valuable lessons for Thailand. This thesis provides suggestions about how to alleviate the deficiencies of, and to enhance, the tax dispute process in Thailand in order to provide increased fairness for Thai taxpayers. These suggestions take the form of proposed policy and legislative reforms, as well as proposed initiatives for the authorities to implement in order to support those reforms. The reform proposals offer various alternatives, allowing the authorities involved in the tax dispute resolution process in Thailand to consider the options that would be appropriate. |
