Real expenses with no receipt can still go in your books, if you know this one document

Part 1One taxi slip, and the question every accountant hits every month

The other night we were testing our bill-extraction system against a stack of documents. One taxi slip for 320 baht sat in the pile. The system read it and came back with a short answer: payee unknown, cannot request a document from the recipient.

Every accountant knows this moment. The money really was paid, the trip was really for work, but the taxi driver has no receipt to give you. Neither does the vendor at the market. A coin-operated parking machine even less so. By month end these expenses pile up, and the same question resurfaces: can this go in as an expense, or do you have to write it off?

The answer is yes, it can go in, and this is not a loophole or a gray-area trick. The Revenue Department wrote the method into its own manual, Preparing Supporting Documents for Bookkeeping That Can Be Claimed as Tax-Deductible Expenses. The main tool for this is called a certificate in lieu of receipt (ใบรับรองแทนใบเสร็จ).

Part 2A three-step ladder before you reach the certificate

A common mix-up: the certificate in lieu of receipt is not the first document to reach for. The Revenue Department arranges this family of documents as a three-step ladder, based on how much the payee is willing to give you.

1. Receipt under Section 105 bis of the Thai Revenue Code (ใบรับ). The payee agrees to issue a receipt, complete with their tax ID number, the issuer's name, book number, document number, date, and full amount. This is the best case.
2. Payment receipt voucher (ใบสำคัญรับเงิน). The payee cannot issue a receipt but is still willing to sign in the payee field. You fill in their name, address, national ID number, the item, and the amount, then have them sign, attaching a copy of the payee's ID card.
3. Certificate in lieu of receipt (ใบรับรองแทนใบเสร็จ). The final step, used when you cannot get anything from the payee, not even a signature. The taxi driver has already driven off, the vendor won't sign, the parking machine is automated. In this case the employee of the business who made the payment certifies the expense themselves.

Seen this way, the question changes entirely. It's no longer "is there a receipt," but "what was the payee willing to give you." Willing to issue a receipt is one step, willing only to sign is another, and unwilling to do either still has a final step to fall back on.

Part 3What the actual form contains

The sample form sits on page 12 of the Revenue Department's manual. It's plain: one line-item table plus one certification paragraph. The table header has four columns.

• Date
• Description of the expense
• Amount
• Notes

Below the table is the grand total, written both in figures and in words, closed with a certification statement that the person claiming the expense must sign, stating that:

the above expense could not be evidenced with a receipt from the payee, and the signer paid it genuinely on behalf of the company.

Two details that many people miss.

First, there are two signature fields. The employee who paid the money, and the approver who holds authority within the company. One person signing as both payer and approver doesn't satisfy the form. It's designed to build in an internal check from the start.

Second, the Revenue Department's sample form has no document-number field. This differs from the receipt under Section 105 bis, where the law requires a book number and document number. In practice, though, we recommend running your own sequential numbering, for example per month per company, because when the record is audited later you can point immediately to which certificate is which and which entry in the accounting ledger it ties to, closing out the review much faster. The manual itself notes that this form is a sample meant to aid understanding and should be adapted to fit each business.

Part 4The certificate alone isn't enough, supporting evidence is what decides it

This is the part that actually determines whether an expense survives an audit or gets added back. A certificate in lieu of receipt is just one piece of paper. Without surrounding evidence, it carries little weight. The Revenue Department's manual is explicit about the supporting evidence you should hold.

• Payment voucher (ใบสำคัญจ่าย). States the payee's name, address, and ID number, the payment date, the type of transaction, the amount, and carries a payment-approval signature from an authorized person only.
• Proof of payment. A copy of a crossed check made out to the payee marked "A/C Payee only," or a copy of a bank transfer. Either one goes a long way toward closing the question of whether the payee genuinely exists.
• Copy of the payee's ID card. Only required for cash payments.
• Internal approval documentation. For example, minutes of an approving meeting, a management memo, or a written expense-approval sign-off. The larger the amount, the more this matters.

The overarching standard covering all of this comes from Section 65 ter of the Revenue Code: the expense must have genuinely occurred, must relate to the actual business, and it must be possible to prove who received the money. If these three conditions hold, even without a receipt, several of the Revenue Department's own rulings have confirmed the expense is deductible. For example, a construction company that bought sand and laterite from local villagers who never issued invoices (letter Kor Khor 0802/14110), or an employee traveling upcountry whose meal and transport costs had no receipts (Supreme Court decision 4963/2536).

Part 5The line you must not cross

This document exists to support genuine expenses that lack complete paperwork, not to conjure expenses out of thin air. Two things to guard strictly.

The payee must genuinely exist and actually work in that trade. The manual states this directly: the payee named in the document must genuinely engage in that occupation. Writing in the name of a vendor who doesn't exist constitutes fabricating false evidence.

The penalty for falsified evidence far outweighs whatever tax you'd save. Section 37 of the Revenue Code sets a prison term of three months to seven years, and a fine of 2,000 to 200,000 baht. As for VAT, input tax on this category of expense is not reclaimable in any case, since there is no tax invoice.

An expense with no receipt isn't a dead end. It just needs the right supporting document, and the genuine expense can go back into the books the way it should.

We run into this every month ourselves, which is why we trained our bill-extraction system to flag this category of bills and draft the certificate automatically. If you have a pile of receipts like this sitting around, you can read how we built it on our AI bill extraction page.

Frequently asked questions

Does a certificate in lieu of receipt need a document number?

The sample form in the Revenue Department's manual has no document-number field, so it isn't mandatory. Still, you should run your own sequential numbering, for example per month per company, so you can audit and cross-reference against the ledger quickly.

How is a certificate in lieu of receipt (ใบรับรองแทนใบเสร็จ) different from a payment receipt voucher (ใบสำคัญรับเงิน)?

A payment receipt voucher is used when the payee is still willing to sign. A certificate in lieu of receipt is used when nothing at all can be obtained from the payee, so the employee who paid certifies it themselves, with an authorized approver signing off as a second check.

Can I reclaim VAT using a certificate in lieu of receipt?

No. Reclaiming input VAT requires a tax invoice only. This set of documents supports the expense side of corporate income tax, and has nothing to do with VAT.

What kinds of expenses qualify for a certificate in lieu of receipt?

Miscellaneous expenses genuinely paid for the business where no evidence can be obtained from the payee, such as taxi fares, fresh-market purchases, coin-operated parking fees, or courier fees. The payee must genuinely exist, and you should attach proof of payment as supporting evidence.