New Guidelines: Individual shareholders can cause companies to be related

Thailand follows the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (‘OECD Guidelines’), and as such, the Thai Revenue Code (‘TRC’) places reporting obligations on certain companies (and juristic partnerships) which have related party transactions. These can include a Transfer Pricing Disclosure Form, Local File, and Country by Country reporting. It is therefore […]

Are you ready for PDPA?

The Personal Data Protection Act or PDPA will come into force on 1 June 2022. With the introduction of the Act so close, your organisation should be preparing for its requirements. However, if your company hasn’t yet started preparing for the PDPA’s requirements, we suggest below four steps which could jumpstart the compliance process. Let’s […]

Update from the Thai Revenue Department regarding the Transfer Pricing Disclosure Form

On 28 March 2022, the Thai Revenue Department (“TRD”) published a Notification of Ministry of Finance regarding TPDF filing deadline extension for FY 2020. Moreover, the TRD also recently issued additional explanation and Q&A for the Transfer Pricing Disclosure Form (“TPDF”) on its TRD website. We have summarised key points as follows: TPDF filing deadline extension […]

Tax Flash: PND 50 / TP Disclosure Form

Filing an annual Corporate Income Tax Return (PND 50) A company or juristic partnership, having its accounting period ended 31 December 2021, is required to submit its audited financial statements and corporate income tax return (PND 50) to the Thai Revenue Department (TRD) within 150 days following the end of the accounting period i.e., on […]

AGM 2022 : No Flexibility on the AGM Deadline this Year

Last year, 2021, the Department of Business Development (DBD) has granted flexibility regarding the deadline for holding the mandatory Annual General Meeting of Shareholders (AGM) in light of the disruption caused by the COVID-19 crisis. However, in this year, 2022, there is no such flexibility anymore. According to the guidelines for filing of the financial […]

Update on Information Exchange and Transfer Pricing Disclosure Form

On the path to enforce the Country-by-Country Reporting (CbCR) requirements in Thailand, there are a few developments regarding the TP rules in Thailand over the past month including the development of information exchange and the newer version of the Transfer Pricing Disclosure Form (TPDF).

Legal Updates: Thailand Approves New Measures to Attract Skilled and Wealthy Expats

The epidemic of coronavirus disease 2019 (“COVID-19”) has been severed and protracted from 2020 until today. As a result, the Thai government has implemented strict epidemic prevention and lockdown measures to prevent the spread. Consequently, gross domestic product (“GDP”) and domestic investment are greatly reduced. Intending to inject foreign money into an economy and to […]

Transfer Pricing Documentation Requirements in Thailand

According to Section 71 bis and Section 71 ter of the Thai Revenue Code, taxpayers that have related parties and earn annual revenue of at least THB 200 million are required to prepare and submit a transfer pricing disclosure form within 150 days after the year-end (the same deadline as the Corporate Income Tax return […]

Legal Updates: Extending the Enforcement Period for Another 3 Years to Modify the Non-Qualifying Building for Hotel Business

On 6 August 2021, the Ministerial Regulations Prescribing Qualifications of Other Types of Building Used in Hotel Business Operation (No.3) B.E. 2564 (2021), issued by the Ministry of Interior, was announced in the Royal Thai Government Gazette in order to extend the period for the buildings which does not meet the requirement for obtaining a Hotel License but provides accommodation service on a short-term basis, which basically deemed […]