Section 156 — Dishonest account auditing for tax
English translation
Whoever, being an official having the duty to audit accounts under the law, dishonestly advises, or does or omits to do any act, so as to cause the omission of entries in the accounts, the making of false entries in the accounts, the alteration of accounts, or the concealment or fabrication of accounting evidence, resulting in a tax or fee not being paid or being paid less than what is due, shall be punished with imprisonment from five to twenty years or imprisonment for life, and a fine from one hundred thousand to four hundred thousand baht.
This English translation is provided for reference only and has not yet been firm-verified — always rely on the Thai original.
Firm annotation
Section 156 completes the trio of revenue-corruption offences by targeting the auditing stage. Its elements are (1) being an official with the legal duty to audit accounts, and (2) dishonestly advising, doing or omitting an act to cause one of the listed accounting manipulations, being omission of entries, false entries, alteration of accounts, or concealment or fabrication of accounting evidence, (3) resulting in unpaid or underpaid tax or fees. It works alongside Section 154, which covers levy and collection, and Section 155, which covers valuation. Notably, this section reaches the auditor who merely advises the manipulation, not only the one who carries it out. It carries the heavy five-to-twenty-year or life range shared by the other revenue offences.
Why this matters in practice
Exposure is five years to life, non-compoundable and prosecuted through the anti-corruption process, and its life-imprisonment ceiling places it in the longest limitation tier. A distinctive feature is that dishonest advice to manipulate the accounts is enough, so an auditing official who instructs or counsels the false entries is exposed even without personally making them. The prosecution must tie the manipulation to an actual or intended tax or fee shortfall. Given the overlap with valuation and collection offences, precise identification of the official's audit duty is central.
Frequently asked questions
Does Section 156 apply to an auditor who only advises the manipulation?
Yes. The section expressly reaches an official who dishonestly advises the false or omitted entries, not only one who makes them.
How do Sections 154, 155 and 156 relate?
They form a graded set: Section 154 covers levy and collection, Section 155 covers valuation, and Section 156 covers dishonest account auditing.