Service Category: Transfer Pricing Consulting

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 […]

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 […]

Update on Country-by-Country Reporting Submission Deadline Extension and Channels

According to the Notification of the Director-General of the Thai Revenue Department (TRD) regarding Corporate Income Tax no. 408 dated 30 Sep 2021, Thai taxpayers who are a part of Multinational Enterprise (MNE) groups with total consolidated revenue of at least THB 28 billion are obliged to submit the Country-by-Country Report (CbCR) to the TRD […]

In step with BEPS transfer pricing rules

Thailand is currently going through a period of rapid improvement and development which is creating opportunities and benefits for foreign businesses. Improvements are being made in many areas, including changes to its tax laws to implement certain international tax standards. Notably, Thailand has adopted the OECD’s Inclusive Framework on ‘Base Erosion and Profit Shifting’ (BEPS) […]

Transfer Pricing Consulting in Thailand

Often driven by the OECD’s Profit Shifting and Base Erosion recommendations, Transfer Pricing is an area of intense scrutiny by tax authorities around the world and can be incredibly expensive for international companies if they cannot evidence and support the arm’s length nature of their related party transactions and become subject to one-sided tax return […]