Nominee Arrangements and CRS: Thailand’s New Data-Driven Compliance Landscape


Original from The Phuket News
What was once considered a grey-area structuring solution has rapidly become a high-risk compliance exposure. In recent months, nominee arrangements have moved back into the spotlight as Thai authorities intensify enforcement efforts—this time powered not just by domestic law, but by global data and tax transparency standards.

A classic nominee arrangement involves a Thai national holding shares on behalf of foreign investors to bypass restrictions under Thailand’s Foreign Business Act B.E. 2542 (1999). Such arrangements have long been illegal, but enforcement was historically driven by complaints, inspections, or isolated investigations. That has now changed.

Since 2024, scrutiny has escalated significantly, driven by Thailand’s full operational maturity under the OECD’s Common Reporting Standard (CRS) and increased pressure from international peer reviews. The result is a shift from reactive enforcement to systematic, data-driven detection.

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