Short Answer
Treat the request as an exception that requires verification—not as automatically illegal and not as routine.
If the contract and invoice identify a company as the supplier, the safest payment route is normally to an account in that company’s name.
Thai Civil and Commercial Code section 315 says that payment must be made to the creditor or to a person authorised to receive payment for the creditor. Payment to someone without authority is effective if the creditor later ratifies it.
So a corporate supplier can potentially direct payment to another person, but the customer should obtain clear corporate authorisation and make sure the payment, invoice, tax and accounting records still tell the same story.
Why This Matters
Changing a bank account sounds administrative.
In reality, a request to pay a supplier’s invoice into a director’s, employee’s or other individual’s account can create several risks at once:
- fraudulent account-change instructions;
- later arguments that the company was never paid;
- difficulty proving authority;
- tax and audit inconsistencies; and
- weak internal controls.
The source matter behind this note involved a company service provider whose proposed payment account belonged to an individual. The review required a corporate account or a separately reviewed corporate authorisation for any exception. The source did not establish that payment to the personal account actually occurred. fileciteturn9file0L19-L22
Typical Scenario
A company has signed a service agreement with a corporate supplier.
The supplier issues an invoice in the company’s name, but shortly before payment an employee of the supplier sends new bank details:
“Please pay this invoice to our director’s personal account.”
Accounts Payable asks whether the payment can proceed.
The answer should not come from the email alone.
Practical Analysis
01Start with the legal creditor.
If the supplier company is the contracting party and invoice issuer, it is ordinarily the creditor.
Section 315 provides that payment should be made to the creditor or a person authorised to receive payment on its behalf.
The key issue is therefore authority—not merely whose name appears on the bank account.
02Verify the instruction independently.
Account-change fraud is common precisely because payment teams are accustomed to acting on email.
Use a known telephone number or existing verified contact rather than replying only to the message containing the new account.
For a personal-account exception, the verification standard should be higher.
03Obtain a corporate payment direction.
The supplier should provide a written instruction from the company identifying:
- the invoice;
- the personal-account holder;
- the bank details;
- the reason for the arrangement; and
- confirmation that payment to that account fully discharges the customer’s obligation to the supplier.
The document should be signed in accordance with the supplier company’s authorised-signatory rules or otherwise supported by appropriate authority.
04Keep the tax invoice in the supplier company’s name.
Payment routing does not by itself change who supplied the service.
For a VAT-registered supplier, Revenue Code section 86/4 requires the tax invoice to identify the registered operator issuing it, including its name, address and tax identification number.
A personal bank account should not be allowed to blur the identity of the supplier for tax documentation.
05Align withholding and accounting records.
Where withholding tax applies, Finance should ensure that the payment direction does not cause the withholding certificate, expense record or vendor ledger to identify a different payee from the actual corporate creditor without a proper basis.
06Consider whether the exception should be rejected commercially.
Even if valid authorisation can be produced, the customer can still adopt a policy that corporate suppliers are paid only into corporate accounts unless a senior exception is approved.
That is an internal risk-control decision.
What We Usually Look At
We review the service agreement, invoice, tax invoice, supplier company affidavit, authorised signatories, written payment direction, bank-account evidence, independent verification record, withholding-tax treatment and vendor master data.
Common Traps
Typical mistakes are treating the request as automatically unlawful, accepting an email from an unverified address, paying first and asking for corporate ratification later, and issuing tax records to the individual simply because the money went to the individual’s account.
Practical Next Step
Use an exception checklist:
corporate creditor → reason for personal account → authorised instruction → independent call-back → discharge wording → tax documents → senior approval
If any link is missing, pay the company account instead.
Legal Sources
- Thai Civil and Commercial Code, section 315, on payment to the creditor or a person authorised to receive payment.
- Revenue Code, section 86/4, on mandatory particulars in a full VAT tax invoice.
- Revenue Department Order No. Por.86/2542, on particulars and preparation of tax invoices under section 86/4.
General legal information only. Please seek advice on your specific facts. Laws and regulatory practice may change.