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
Head of Tax Department
Philip has over 35 years’ experience in the corporate and international tax, most of which with PwC and KPMG in the UK, Africa, the Middle East, and Thailand.
Notably, Philip worked as a tax partner for KPMG, and for a time was the Head of Tax for PwC in Mauritius – roles which provided invaluable practical experience, real insight into different cultures, tax authorities, tax laws and practices, and how the different internal tax departments of KPMG and PwC operated.
- Various senior roles with UK companies including Aerospace Communication Systems, British Steel, Marconi Communications, and Coopers & Lybrand / PwC 1984 to 2002
- PwC Tanzania and PwC Zambia 2002 to 2005
- Tax Director with KPMG Thailand 2005 to 2008
- Head of Tax, PwC, Mauritius 2008 to 2010
- Tax Director/Partner KPMG, Oman, Middle East 2010 to 2013
- Head of Tax and Legal Support, PKF International 2013 to 2018
- Various roles dealing with international corporate tax matters, PKF 2018 to 2020
- Partner, PKF Thailand 2021
- Banking and financial services
- Power, water and utilities
- Retail and consumer goods
- Service industries
- Travel, tourism and hospitality
- Chartered Accountant (Fellow, ACCA, UK)
- Chartered Tax Adviser (Associate, Chartered Institute of Taxation, UK)
- Associate Member of the Association of Accounting Technicians
Steve has 30 years’ international tax experience gained in London, Singapore, Moscow, Gibraltar and Bangkok working for Big 4 consulting firms and as Head of International Tax for one of the world’s largest oil companies. He specialises in international tax, transfer pricing, corporate treasury transactions, cross-border structuring and managing contentious tax issues including corporate tax and VAT audits.
- Oil and Gas
- Banking, Securities and Financial Services
- BA Economics
- MBA (London School of Economics and New York University)
- Chartered Tax Advisor (UK)
- Member of the Association of Corporate Treasurers (UK)
- Advanced Diploma in International Taxation (ADIT)
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