Bookkeeping duties of a company registered in Thailand — who must keep accounts, who may prepare them, and record retention

The Accounting Act B.E. 2543 separates two roles. The "person with the duty to keep accounts" is the juristic person itself: a limited company, public company, registered partnership, or the Thai branch of a foreign entity. The "bookkeeper" is the individual who actually records entries and prepares the financial statements.

Legal responsibility for complete and accurate books stays with the duty-bearer even when an outside accounting firm is engaged. Directors should therefore keep a record of what was handed to the bookkeeper and when. If records go missing, a government reviewer looks at the company first.

Companies with foreign shareholders or directors often assume the accounting firm absorbs the whole obligation. That is not how the law is built. The engagement letter should state who supplies which documents, for which period, and who approves the statements before filing.

Accounts must be kept in Thai. Where they are kept in a foreign language, Thai must accompany them under the applicable notification. A company running an English-language ledger supplied by its parent needs a translation or dual-language method that remains auditable later.

Foreign contracts, overseas supplier invoices and foreign bank confirmations are supporting records that an officer may ask to see in Thai. Translations used with a government agency should carry a translator’s certification of accuracy, and in some cases a Notarial Services Attorney’s certification as well.

The Accounting Act sets a retention period for books and supporting records kept at the company’s place of business, and the Revenue Code can set separate periods for certain tax documents. Use the longer of the two as your rule, and confirm the current periods with the DBD and the Revenue Department.

A company using a virtual office as its registered address should be clear about where the books are physically kept. Moving the place where accounts are stored requires approval or notification as the law prescribes, and an officer may inspect at the declared location.

Under the Accounting Act, a company must have a bookkeeper who meets the qualifications set by the Department of Business Development, but responsibility for proper books still rests with the company and its directors. Outsourcing to an accounting firm does not transfer all of that responsibility. Directors should know who the bookkeeper is, whether they receive complete documents, and whether the statements follow the financial reporting standards that apply to the company.

Bookkeepers must register with the Department and keep up continuing education as required, and a company can ask to see evidence of registration. When changing bookkeeper, hand over documents, balances and data files in writing so records do not break.

Every entry should be supported by a document, such as a tax invoice, receipt, invoice, contract, payment voucher, bank statement or withholding tax certificate. Expenses without documents, or with documents not in the company’s name, may not be deductible under the Revenue Code, which raises the tax due.

The law requires books and supporting documents to be kept at the place of business for the prescribed period, and electronic storage is allowed under the applicable rules. File them by month and type, and keep an off-site backup so they are ready when the auditor or officials ask.

A company with no income still has to keep books, prepare financial statements, have them audited and file tax returns as usual. Not filing because there seems to be nothing to report can lead to penalties. Another misunderstanding is receiving company money into a personal bank account, which makes records hard to separate and can cause problems on inspection. Use an account in the company’s name for all company transactions.

Monthly: send the bookkeeper a full set of income and expense documents, new contracts and bank statements. Check that tax invoices received show the company’s correct name, address and tax ID, and ask for a short report such as a trial balance or cash position so directors see the real financial picture.

Quarterly: review old receivables, unpaid payables and director advances for supporting documents. Money lent between directors and the company should have a written agreement and clear records, as these are often questioned in audits and tax reviews.

Annually: count inventory and assets, review the asset register, prepare meeting minutes, and plan the year-end close with the bookkeeper and auditor from the start of the year.

Must books be in Thai? Books must be kept in Thai, or in a foreign language with Thai alongside, under Department of Business Development rules. Companies with foreign management therefore often use bilingual reports.

Can we use online accounting software? Yes, if it records data completely, keeps an audit trail and can export data when officials or the auditor ask. Set user permissions and back up regularly.

What if past records are incomplete? Gather bank statements and whatever documents exist, then have the bookkeeper reconstruct the books from evidence. Avoid creating back-dated documents that do not reflect reality, which can be a more serious offence than filing late.