Supreme court orders enforcement to collect 17.6bn baht tax on Thaksin’s shin corp share sale

• The Supreme Court overturned earlier rulings and ordered enforcement to collect 17.6bn baht in taxes, surcharges and interest from Thaksin Shinawatra.
• The court ruled that the use of nominees to hold Shin Corp shares to bypass political office restrictions was unlawful and lacked “tax morality”.
• The decision reverses previous rulings by the Central Tax Court and the Specialised Appeal Court, which had earlier cancelled the Revenue Department’s tax assessment.
• The Revenue Department must now proceed with enforcement, expected to take 1–2 months before issuing a formal enforcement order.
• The tax liability stems from Thaksin’s sale of Shin Corp shares via Ample Rich Investment to Singapore’s Temasek Holdings. 

The Supreme Court has overturned earlier rulings and ordered the enforcement of tax collection amounting to 17.6 billion baht from former prime minister Thaksin Shinawatra, relating to the sale of Shin Corporation shares.

On November 17, 2025, at the Tax Court on Chaeng Wattana Road, the Supreme Court’s Tax Litigation Division read its verdict in the case filed by Thaksin Shinawatra (plaintiff) against the Revenue Department (first defendant), Pongsak Metaphiphat (second defendant), Prapas Sanansilp (third defendant) and Pisit Sriwaranan (fourth defendant).

Thaksin had asked the Central Tax Court to revoke the personal income tax assessment (Form PND.12), reference number PND.12-03025250-25600328-001-00005, dated March 28, 2017, which ordered him to pay 17.6 billion baht in personal income tax — including tax, surcharges and additional interest — to the Revenue Department in connection with the Shin Corporation share sale.

The Supreme Court found that Thaksin concealed his actual shareholding in Shin Corp by using nominees — including Panthongtae Shinawatra and Pintongta Shinawatra — to hold shares on his behalf. The intention, the court said, was to bypass legal prohibitions that prevented individuals holding Shin Corp shares from taking political office.

The court ruled that this arrangement was made “for a purpose lacking tax morality”, was inconsistent with the spirit of Thai tax law, and prevented the state from collecting tax correctly and fairly. It said the nominee transaction had no genuine economic rationale beyond securing improper tax advantages, rendering it an unlawful act of serious misconduct.

Because of this, the court held that there were no grounds to waive or reduce penalties or additional charges. It also found that other issues in the case did not affect the outcome and therefore did not require further ruling.

The ruling reverses the previous decisions of the Central Tax Court and the Specialised Appeal Court (2023).

Both had ruled in Thaksin’s favour, finding that the Revenue Department’s tax assessment was unlawful because proper procedures — including a summons under Section 19 of the Revenue Code — were not followed.

However, after the Revenue Department filed a petition, the Supreme Court accepted the appeal and dismissed Thaksin’s complaint, reinstating the full tax liability.

Following the ruling, the Revenue Department must now proceed with enforcement measures to collect the 17.6bn baht. Officials expect it will take one to two months for the court to issue a formal enforcement order.

The tax claim stems from Thaksin’s sale of Shin Corp shares to Singapore’s Temasek Holdings, executed through Ample Rich Investment Ltd. The transaction became a key issue in Thai politics, leading to years of legal disputes.

Reporters noted that earlier, the Central Tax Court had issued a ruling in Black Case No. Por 220/2020 and Red Case No. Por 109/2022, dated July 18, 2022, cancelling the personal income tax assessment (Form PND.12).

The court found that Revenue Department assessment officers had failed to issue a summons to the plaintiff (Thaksin) under Section 19 of the Revenue Code as the principal actor. As a result, the issuance of the PND.12 tax notice was deemed unlawful.

Subsequently, on June 2, 2023, the Specialised Appeal Court (Tax Division) delivered Judgment No. 2819/2023, upholding the Central Tax Court’s decision.