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 adjustments, penalties, surcharges and having to deal with protracted tax authority enquiries.
A proactive, technically sound, and consistent approach to transfer pricing by international companies will always be a better strategy than a reactive response involving tax authority enquiries, disputes, and audits. This is even more relevant today with the emphasis on transparency and wide-ranging exchange of information between tax authorities, and especially now that Thailand has signed the OECD’s Multilateral instrument.
PKF can assist your Company with the:
■ Completion and submission of the annual Transfer Pricing Disclosure Form (Return), as required under Thai Law for companies with related parties and an annual turnover of THB 200 million or more.
■ Provision (preparation and completion) of a Transfer Pricing Local File for a particular year based on Thai and OECD Transfer Pricing Guidelines, which can be requested by the TRD for submission within 60 days.
■ Provision (preparation and completion) of a Country-by-Country (CbC) Report for a particular year based on Thai and OECD Transfer Pricing Guidelines.
■ Provision (preparation and completion) of a Transfer Pricing Master File for a particular year based on Thai and OECD Transfer Pricing Guidelines.
PKF can also assist your Company by:
■ Reviewing Management Agreements, Services Agreements, Loan agreements, etc., with overseas related companies to advise you on the Thai transfer pricing exposures to the Company so action can be taken to make such agreements more robust and acceptable to the TRD (tax authority). In addition, we will also advice you on the withholding tax, and VAT implications of any international payment or service fee.
Our specialist Transfer Pricing team includes very experienced tax professionals and economists with specialist academic and professional qualifications who have worked in various European, Middle East, Asian, and African countries, as well as the United States. The team has accumulated significant experience in delivering Transfer Pricing assignments in South-East Asia in a wide range of industries including financial services, food processing, manufacturing, energy, petrochemicals, commodities, microelectronics, security services, shipping, retail and consumer products, hospitality, pharmaceuticals, and e commerce.
If you require any transfer pricing assistance, our specialist PKF Transfer Pricing team based in Bangkok would be delighted to hear from you and provides a full range of local and international transfer pricing services – please get in touch.
Transfer Pricing Services
- Preparation/review of TP documentation including CbCR, Master File, Local File and TP Disclosure Form
- Preparation/review of Advance Pricing Agreements
- Preparation/review of TP methodologies and policies
- Local/regional/global benchmarking studies
- Industry, economic and functional analyses
- BEPS proof TP health checks
- Responses to TP enquiries, disputes, and audits
- Advising on TP risk management and performing interim TP risk reviews
- Advising on TP dispute resolution, arbitration, and tax treaty issues
- Advising on the TP implications of business restructurings
- Reviewing related party agreements for sales and purchases, loans, services, royalties, and transfers of intangibles
- Assist clients to prepare annual corporate income tax and mid-year corporate income tax calculations and tax returns (PND 50 and PND 51), including tax calculations for BOI and to assist clients to review monthly tax returns for compliance
- Prepares personal income tax computations and tax returns
- Provides advice on corporate income tax, international tax, tax planning and transfer pricing
- Manage and deliver transfer pricing compliance services including preparation and review of transfer pricing documentation (Local File and Master File), review of Thai transfer pricing disclosure forms, performance of local benchmarking analyses
- Provides advice on inheritance tax
- Assists with tax authority audits
- Performs tax reviews and tax due diligence
- Service business
- Master of Arts in Economic Law (Taxation) from Chulalongkorn University
- Bachelor of Business Administration (Accounting) from Srinakharinwirot University
- Active Tax Auditor (TA) licenses in Thailand
- Experienced in the Credit Analysis of Japanese and Thai corporates
- Previously responsible for Financial Analysis and Liquidity Management at one of Thailand’s largest corporates
- Focus on Transfer Pricing advisory services and deliver transfer pricing compliance services including preparation of transfer pricing documentation, performance of benchmarking analyses
- Manages Transfer Pricing Documentation assignments
- Master of Management from the College of Management, Mahidol University
- Bachelor of Economics with second-class honors from Kasetsart University
- KPMG Tax and Legal
- Deloitte Touche Tohmatsu Jaiyos
- KPMG Peat Marwick Suthee
- SGVN Legal and Tax Consultants
- Finance and Banking
- Service business
- MBA Yonok College
- LLM Chulalongkorn University
- LLB Chulalongkorn University
PKF is here to help
Find out how PKF can help you get closer to your goals