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

Key clients

Key People

Apinun Ittivarapornkul

Tax Manager

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Theeradaje Tansuwanrat


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