Transfer Pricing Consulting in Thailand

Transfer Pricing (TP) is an area of intense scrutiny by tax authorities around the world. Large Multinational Enterprises (MNEs) can be exposed to very significant tax risks if they do not pay close attention to TP. There can be significant risks of multiple taxation, fines and penalties for non-compliance, and large costs in dispute resolution. These risks are all too apparent with the emphasis on transparency and wide-ranging exchange of information between tax authorities.

A proactive, technically sound, and consistent approach by MNEs to TP will always be a better strategy than a reactive response to TP disputes and audits.

The Thai Revenue Department (TRD) has responded to OECD initiatives by introducing wide-ranging TP legislation with the three-tier TP documentation requirements now a core part of Thai TP legislation.

PKF provides a full range of TP services from preparing and reviewing TP documentation and advising on TP compliance matters to complex TP consulting assignments. 

The TP team includes experienced professionals with specialist academic and professional qualifications who have worked in the UK, Singapore, Russia, Gibraltar, and Thailand. The team has accumulated significant experience in delivering TP 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. 

The PKF global network is always available to provide support for the successful delivery of TP assignments to large listed and unlisted companies as well as fast growing companies.

The TP team is based in Bangkok and able to deliver TP assignments through our offices in Bangkok, Chiang Mai, Hua Hin, Pattaya, Phuket, Sriracha and U Tapao.

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

Key clients

Key People

Philip Bond

Head of Tax Department

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