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 […]

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 […]

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) […]