Saravut’s principal focus for the past two decades is on tax, corporate restructuring and cross border M&A. His primary focus on taxation and restructuring experience extends across several practice areas including corporate, mergers and acquisitions, capital markets including initial public offerings for various industries, in particular, the oil and gas industry. He is an esteemed legal expert in the oil and gas industry having represented some of the largest investments in petroleum exploration and production in Thailand.
Apart from oil and gas, Saravut has extensive experience in real estate, technology start-ups and the e-commerce industries. He provides legal and tax counsel including risk management advice for the restructuring and entire business transfer (EBT) of groups of companies as well as providing tax management and planning advice on setting up proper entities for investment and development projects in ASEAN countries. He also advises property developers on a spectrum of tax structures for real estate acquisitions including income tax, withholding tax, VAT, SBT, stamp duties through to house and land tax.
Languages
Publications and Presentations
- Author of the whitepaper “Legal Status of Digital Assets from the Corporate Income Tax Perspective according to the Thai Revenue Code” for Thailand’s Office of Judicial and Legal Affairs of the Court of Justice as part of “Dunlaphaha: Journal of the Court of Justice.”
- Author of Thailand Tax Update: Further Deferral of Tax Filings and Payments
- Author of Thailand Tax Update: COVID-19 and Tax Relief Measures in Thailand
- Speaker on “Cross Border Investment Activities Between Countries” ALB Thailand In-house Legal Summit 2019.
- Author of “Thailand issues regulation on stamp duty payment for electronic documents”, International Tax Review (ITR).
Awards and Recognitions
- Notable Practitioner in Tax by Asialaw, 2021
- Notable Practitioner in Restructuring and Insolvency by Asialaw, 2021
- Recommended Lawyer in Tax by Legal 500 Asia Pacific, 2020
Education
- LL.M, Private Law, Thammasat University, Thailand
- LL.B, Thammasat University, Thailand
Professional Qualifications
- Director Accreditation Program (DAP) – 185/2021, Thai Institute of Directors (IOD)
- Advanced Audit Committee Program (AACP) – 41/2021, Thai Institute of Directors (IOD)
- Extra-ordinary Member, the Thai Bar Association
- Member, the Lawyers Council of Thailand
A selection of matters in which Saravut has been involved include:
Tax and Corporate Restructuring
- Representing multinational companies in tax dispute matters in connection with transfer pricing, withholding tax and VAT, including defending a case against the Thai Revenue Department.
- Representing a leading Thai renewable energy company on tax planning for the client to protect its investment under a reasonable effective tax rate in solar power plants in Lao PDR as the operations and repatriation of investment will affect the operation plans.
- Representing PTT Public Company Limited regarding the tax planning structure in a merger among its subsidiaries.
- Representing Sea Oil Public Company Limited on VAT assessment and mitigation of VAT penalty including tax planning for VAT refund.
Corporate and M&A
- Representing IRPC PCL., a Thai Public SET-listed petroleum and petrochemical company and a subsidiary of PTT Group as legal and tax counsel in connection with its potential share acquisition of 50% of Mytex Polymers (Thailand) Co., Ltd. from its current shareholders, Japan Poly Propylene Corporation Limited (JPP).
- Representing IT City Public Company Limited, a leading technology retail superstore chain as lead legal and tax counsel to acquire 100% of the shares in Computer System Connection International Co., Ltd. (CSC), a smartphone retailer at the total value of THB 346 million (USD 11.1 million)
- Representing various multinational corporations in connection with conducting legal and tax due diligence and addressing relevant key legal and tax issues concerning multiple merger and acquisition transactions.
Payment system works and banking laws
- Representing one of the world’s largest FinTech companies as legal and tax counsel in Thailand.
- Representing one of the world’s largest oil companies as tax counsel in connection with client’s implementation and use of DocuSign, a digital solution that enables the management of transactions in an all-digital environment, a form of digital transaction management system for the contracts of the Company in particular on stamp duty implications.
- Representing Sea Limited – group companies in Thailand on its application for licenses and permits from the Bank of Thailand in relation to payment systems, payment agent, e-payment agent and platform, e-money, and related matters.
Personal Data Protection Act and Cybersecurity Protection laws
- Representing and providing advice to Business Online PLC and its group of companies on the Personal Data Protection Act (PDPA) and the Cybersecurity Act.
- Representing several Thai companies in providing advice on the Personal Data Protection Act and the Cybersecurity Act.
Industry Focus: Oil & Gas
Petroleum Laws and Natural Resource
Saravut’s legal experience in the oil and gas sector throughout his career has further strengthened his knowledge of the petroleum laws, natural resource laws, petroleum income tax and other laws related to transactions of participating interest in petroleum concessions and operation of petroleum activities in Thailand, which are exemplified by his representation of some of the leading companies in this sector.
- Advising Chevron Thailand Exploration and Production Ltd. on rules and regulations related to decommissioning matter, regulatory requirements, and impact of the regulatory requirements to the rights and duties of concessionaire under the petroleum concession agreements.
- Representing Twinza Oil Limited in connection with criminal case on trespassing forest area and agricultural land reform area for petroleum exploration and production.
- Advising Twinza Oil Limited on petroleum laws, natural resource laws and regulations including:
- usage of land and natural resources for petroleum exploration and productions;
- overlapping of relevant government authorities in relation to use of land and natural resources for petroleum exploration and production; and
- rights and duties of concessionaire under the concession agreements.
Capital Markets
- Representing various private companies on amalgamation with other limited companies and converting them into public company limited
- companies including advising on the regulations of the Securities and Exchange Commission (SEC) and Stock Exchange of Thailand (SET) to prepare for initial public offerings (IPO) on SET.
- Representing Krung Thai Asset Management Public Company Limited in its capacity as a REIT trustee for the launch of WHA Business Complex Freehold and Leasehold Real Estate Investment Trust (WHABT), Thailand’s first-ever office building REIT, worth THB 4 billion (approximately USD 111.1 million).
