Transfer Pricing Advisory

Thailand’s transfer pricing rules require up to date transfer pricing documentation for international and domestic related party transactions.

Baker Tilly Tax Thailand can assist with both the preparation and review of Thai transfer pricing documentation, functional analysis and benchmarking, Country by Country three tiered reporting, Revenue Department Transfer Pricing investigations as well as Advanced Pricing Agreements (APA) for approval by the Revenue Department.

On 3 January 2018, the Thai Cabinet approved the draft specific transfer pricing legislative provisions after public consultation during 2017. This will introduce further more specific transfer pricing provisions into the Revenue Code. The draft Act requires MANDATORY transfer pricing disclosures to be made within 150 days from year-end closing date. The Draft is currently in the legislative process by the National Legislative Assembly.

Accordingly, having the correct, up to date, Thai transfer pricing documentation and reviews in place forms a part of having a robust corporate governance framework as well as mitigating the tax risk of audit adjustments and penalties.

Our team has experience in dealing with local and international management and finance functions in terms of their Thai transfer pricing needs in view of a Group’s global transfer pricing policies.