Transfer pricing is a 'soft target' for tax authorities as there is no absolute rule for determining the 'right' transfer price, royalty or service fee.
In Thailand, the Revenue Department has issued the Departmental Instruction No. Paw 113/2545 ('D.I. No. Paw 113/2545), which requires all companies with inter-company transactions to prepare and maintain contemporaneous transfer pricing documentation at their office.
Enforcement of the Transfer Pricing Guidelines will enable the Revenue Department to gauge transfer pricing practices of multinational companies and identify potential audit targets on the transfer pricing issue (i.e. multinational companies that adopt a transfer pricing mischief).
Are you ready to justify your transfer pricing practices and demonstrate that there is no unfair transfer of profits out of Thailand?
Stricter penalties, new documentation requirements, increased information exchange, improved training and specialisation are likely to be some of the tools used by the Revenue Department. To comply with transfer pricing rules, our Transfer Pricing Team will work with you to develop an overall comprehensive tax planning strategy.
Key Transfer Pricing Services
