It is with great sadness that we note the passing of Professor Paichitr Rojanavanich (ศ.ไพจิตร โรจนวานิช, Full Professor), who served as an advisor to our firm for many decades. We would like to express our deepest condolences and respectfully offer our sincere prayers for his soul to rest in peace.
On this occasion, I would like to briefly explain the background leading to our introduction to him, although the circumstances were somewhat complex.
Approximately two years after my office was established in Thailand (founded in 1993), the first person I had the honor of meeting was Dr. Panus Simasathien (ดร. พนัส สิมะเสถียร, Director-General of the Revenue Department, former Permanent Secretary of the Ministry of Finance, and former Minister of Finance). I began to realize the need for advisors for the office, so I sought advice from Mr. Yuji Gomi (former Deputy Director-General of the Japan National Tax Agency, who had been one of my former superiors), asking if he could recommend suitable individuals. He kindly recommended two people: Professor Paichitr Rojavanich and Mr. Wit Tantayakul (former Director-General of the Revenue Department and former Director-General of the Electricity Generating Authority of Thailand (EGAT)). Mr. Gomi had served as Chairman of SGATAR (Study Group on Asia-Pacific Tax Administration and Research), and I had often heard from him that he had a particular fondness for Thailand and had developed close relationships with senior tax officials at the time, including Dr. Panas who was then the Director-General of the Revenue Department. It was for this reason that I sought his advice. Mr. Gomi graciously agreed to my request and arranged an introduction to Dr. Panas. When I visited Dr. Panas to ask whether he would consider serving as our advisor, he kindly explained that his own background was primarily in tax administration, and that if we were seeking specialists in tax matters, he recommended others more suitable. It was at that point that he introduced us to Professor Paichitr Rojanavanich and Mr. Wit Tantayakul.
At that time, I was extremely busy, to the point of barely having time to sleep. Amidst this situation, Mr. Vit sadly passed away suddenly, and as a result, we proceeded to ask Professor Paichitr to assume the role of our advisor.
I recall that when Dr. Panas was serving as Permanent Secretary, Professor Paichitr held the position of Deputy Permanent Secretary. They were also alumni of the same institution, and I myself was fortunate to have many opportunities to dine with both of them thereafter. Even so, I remember that it took nearly another two years before Professor Paichitr finally agreed to accept our request to serve as an advisor. I was later told that he had been carefully observing the reputation and standing of our firm during that period. In the case of Japanese civil servants, it is often said that post-retirement positions are, so to speak, informally arranged within the ministry, with individuals settling into what are commonly referred to as Amakudari appointments. From that perspective, one might find it striking that Professor Paichitr exercised such personal deliberation and caution before reaching his decision to work with us.
Professor Paichitr provided us with invaluable advice on numerous particularly difficult tax matters, far too many to enumerate. Please allow me to share one specific example.
Around 2006, during a lunch buffet at Pathumwan Princess Hotel, Professor Paichitr suddenly asked me, “Is Ariya all right?” He looked genuinely concerned, saying that he had heard a reputation that Ariya was “too tough,” and wanted to know whether everything was indeed in order. As he went on to explain, it became clear that his concern stemmed from a particular case involving a client’s tax refund. The matter had proven extremely difficult, as it was a troubling case in which a Japanese CPA from a large-scale accounting firm in Thailand was alleged to have demanded a bribe, making it an especially problematic and sensitive situation.
I explained, “We are simply asserting what is right. We have done nothing that is not based on the law. In fact, this case concerns a tax refund matter that had originally been handled by a large-scale accounting firm, where a partner allegedly acted behind the scenes, insisting that a bribe was necessary, which only served to complicate the situation. After that, the client came to Ariya. As a result, the matter has taken a considerable amount of time from the outset, and above all, the case was inherently problematic because of the improper handling by the initial consultant. As a firm, we are merely insisting on what is entirely proper, namely, to obtain the tax refund in accordance with the law, as well as the applicable refund interest, but it has been an extremely difficult process.”
Professor Paichitr responded, “If that is the case, then it is rather a matter of honor. As for the alleged bribery, I will also make some inquiries on my side to see whether such conduct actually took place.”
I should also note that I have written elsewhere about this Japanese CPA, who was, at the time, also a representative partner of another large-scale accounting firm. Subsequently, Professor Paichitr informed me that the head of the relevant tax office was well known as a person of unquestionable integrity, and that, according to the head of the office, there were no indications that any of his subordinates had engaged in such conduct. On that basis, Professor Paichitr commented that the allegation of bribery was, in all likelihood, questionable.
Professor Paichitr’s Commentary on the Revenue Code (ภาษีสรรพากร : คำอธิบายประมวลรัษฎากร, co-authored with Mr. Saroch Thongpracum and Mr. Chumphon Sensai), is an authoritative work that can invariably be found on the desks of Revenue Department officers. Incidentally, when I asked Gemini about Professor Paichitr Rojanavanich, it responded as follows: “Professor Paichitr Rojanavanich is one of the foremost authorities in Thailand’s tax administration, having served as Director- General of the Excise Department and built his career across key departments within the Ministry of Finance. In the fields of Thai taxation and accounting, it is fair to say that there are very few practitioners who are unfamiliar with this book; it is regarded as one of the most trusted and widely read commentaries on tax law.”
Thanks to the contributions of Professor Paichitr’s book, many Japanese companies have received fair tax treatment. In principle, such fair treatment from tax law enforcement agencies is something to be expected. However, considering the nature of large organizations, achieving it in practice can be difficult. On several occasions, I was asked by the directors of the Large Business Tax Administration Office (LTO), “What does Professor Paichitr say about this matter?” This, in my view, was not merely a reflection of his distinguished career, but rather a testament to his profound knowledge, sound judgment, and personal integrity.
When considering tax matters, Professor Paichitr taught us the importance of first examining the statutory provisions, then reviewing relevant judgement, and, in doing so, carefully reflecting on the underlying legislative intent. For example, in applying the VAT reverse charge mechanism, including the application of P.P. 36, he emphasized the need to consider the objective of ensuring fairness in capital export neutrality. This way of thinking is a precious legacy that our firm learned directly from him. He also taught us to place our trust in Thailand’s tax administration, emphasizing its commitment to operating in accordance with the rule of law. This belief is, for me, one of the very reasons why I feel that it was worthwhile to have pursued this profession in Thailand.
At the funeral, I had the opportunity to meet his son, Mr. Suwit Rojanavanich, former Director of the Public Debt Management Office and former Director-General of the Fiscal Policy Office (FPO), for the first time. When Mr. Suwit was serving as Director-General of the Fiscal Policy Office (FPO), he stated in an interview with the Post Today newspaper: “Being a civil servant is seen as a somewhat outdated career path; it’s no longer at the forefront because the pay is low and the lifestyle is modest. Compared to the private sector, there is a massive gap in prestige and luxury across every dimension. To survive as a civil servant, you must lead with your heart—otherwise, you won’t endure the system. You need a strong, unwavering commitment to the idea that your work is for the greater good of the nation.” I wonder how many civil servants in Japan today can express such ideals so frankly, which are so reminiscent of his father’s. It is likely that many Japanese residents in Thailand are unaware that there are civil servants of such integrity spanning two generations within Thailand.
During the funeral of Professor Paichitr, I had the opportunity to speak with another of his sons. He politely stated that we no longer needed to pay his father the consulting fees. I was impressed by his honesty and composure.
Over the years, I have encountered numerous Japanese “experts” who casually claim that requesting a tax refund in Thailand will only result in having even more tax assessed. Such statements are deeply regrettable—especially when expressed by Japanese professionals. This has led me to reflect once again on how difficult it truly is to observe and understand the systems of another country accurately and fairly.
With the exception of Dr. Panas, I can no longer meet any of the seniors mentioned here. This simply means that I, too, have grown older, and there is no particular reason to be astonished by that fact—yet, even so, I cannot help but feel a sense of astonishment.
We are deeply grateful for his many years of dedicated guidance and generous support. We respectfully express our deepest condolences.
Major Career Positions of Professor Paichitr
• Deputy Permanent Secretary, Ministry of Finance
• Deputy Director-General, Revenue Department
• Deputy Director-General, Customs Department
• Director-General, Treasury Department
• Director-General, Excise Department
