Adirek is a partner of Rajah & Tann (Thailand) Limited.
Adirek brings more than 30 years of extensive experience advising multinational corporations, financial institutions, listed companies, private enterprises and family-owned business groups on sophisticated domestic and cross-border business transactions. He is recognised for integrating legal, commercial and tax considerations to develop practical, commercially focused and tax-efficient solutions for complex corporate transactions, strategic investments and business reorganisations.
His practice focuses on Thai and international taxation, cross-border investments, mergers and acquisitions, corporate restructurings, transfer pricing, tax treaty interpretation, customs and indirect taxation, tax controversy, and corporate and commercial law. He has extensive experience advising on tax-driven corporate reorganisations, including mergers, amalgamations, Entire Business Transfers (EBT), Partial Business Transfers (PBT), share acquisitions, holding company restructurings, business separations and post-acquisition integrations implemented under the Thai Revenue Code and related Royal Decrees.
EXPERIENCE
Adirek commenced his career with SGVN Legal and Tax Ltd., the Thailand legal and tax practice of Arthur Andersen. Following the integration of Arthur Andersen with KPMG, he continued his practice with KPMG Phoomchai Tax & Legal Ltd. Prior to joining Rajah & Tann (Thailand), he was a founding partner of KNSAT Associates Legal & Tax Co., Ltd., where he co-led the firm’s Tax and Corporate Practice.
Throughout his career, Adirek has advised boards of directors, multinational corporations, listed companies and private business groups through every stage of domestic and cross-border transactions, from transaction structuring, legal and tax due diligence, investment planning, regulatory analysis and negotiation to implementation and post-completion integration.
Selected Notable Cases & Representation
Tax & International Tax
- Served as Thai tax counsel to DLA Piper LLP (US) over a number of years on complex cross-border transactions involving multinational corporations investing in Thailand.
- Advised AIA on the Thai tax aspects of employee stock option plans, executive compensation arrangements and employee incentive programmes.
- Advised Citibank, American Express (Thai) Co., Ltd. and Diners Club (Thailand) Co., Ltd. on Thai corporate taxation, international taxation, financial services regulation and commercial matters.
- Advised multinational corporations on transfer pricing, double taxation agreements, permanent establishment issues, withholding tax, VAT, customs duties, tax-efficient financing structures, licensing, royalty and management service arrangements.
- Advised foreign investors on inbound investments, regional holding structures, tax incentives, investment structuring and post-acquisition integration.
Corporate Reorganisation, Mergers & Acquisitions
- Advised on numerous mergers, amalgamations, Entire Business Transfers (EBT), Partial Business Transfers (PBT), share acquisitions, holding company restructurings, business combinations and group reorganisation projects involving listed companies, multinational corporations and privately-owned business groups.
- Advised on tax-efficient restructuring projects implemented under the tax exemption provisions of the Thai Revenue Code and related Royal Decrees.
- Advised Premier Group, Winnergy Group, Usha Siam Steel Industries PCL, Alpla Packaging (Thailand), Baiyoke Group, Thriven Group, Wisco Alliances, Metro Machinery Group, KKF International Group, FN Factory Outlet, Home Sukkapan, Wang Thong Group and other business groups on mergers, acquisitions and strategic restructuring projects where personally involved.
- Advised on transaction structuring, acquisition vehicles, legal and tax due diligence, shareholder arrangements, implementation and post-acquisition integration.
Banking & Structured Finance
- Advised Siam Industrial Credit Public Company Limited on the tax aspects of THB 4 billion and THB 3 billion securitisation transactions involving special purpose vehicles.
- Advised Siam Panich Leasing Public Company Limited on the tax aspects of a THB 2.5 billion securitisation transaction.
- Advised financial institutions and corporate clients on the tax implications of structured finance, financing arrangements and capital market transactions.
Corporate & Commercial
- Advised multinational corporations and leading Thai enterprises on foreign investment, Foreign Business Act compliance, BOI-related matters, commercial contracts, shareholder arrangements, corporate governance, legal and tax due diligence and regulatory compliance.
- Advised clients including Canon, Aramex, Halliburton, Bangkok Patana School, HomePro, Big C, Konica Minolta, Sojitz, Scania, Zuellig Pharma and numerous undisclosed multinational corporations on Thai legal, tax and regulatory matters.
Customs & Tax Controversy
- Represented multinational corporations in customs valuation disputes, customs appeals, anti-dumping matters and negotiations with the Thai Revenue Department.
- Advised clients on customs valuation, tariff classification, import duty planning, tax audits, tax appeals, indirect taxation and dispute resolution strategies.
MEMBERSHIPS / DIRECTORSHIPS
- Extraordinary Member, Thai Bar Association
- Lifetime Member, Lawyers Council of Thailand
- Notarial Services Attorney
