We help design and implement Global TP Policy / review Agreements for Multinational Corporations. We also provide TP litigation support services.
Transfer Pricing compliance requirements by delivering meticulously prepared Documentation as per Local TP Regulations and global standards.
We assist in identifying gaps by providing health check up from Legal, Corporate and TP documentation perspective.
We have access to various public financial and company databases, industry and directories which assist us to render comprehensive TP analysis.
The tax provisions and the Thai Transfer Pricing Guidelines are also applicable to domestic transactions, as well to cross border transactions.
The Transfer Pricing Law of 21 November 2018 introduced a requirement to submit an annual TP disclosure form. On 7 November 2019, the Revenue Department issued the Notification of the Director-General of Revenue Department defining the content of the TP disclosure form. The TP disclosure form was published on 18 November 2019. On 15 March 2020, the Revenue Department issued guidance on the TP disclosure form. On 14 January 2021, the Director-General of Revenue issued a notification to make online filing of the TP disclosure form mandatory for accounting periods beginning on or after 1 January 2020. The taxpayer had the choice of paper or online filing for accounting periods beginning on or after 1 January 2019.
The Transfer Pricing Law of 21 November 2018 introduced a requirement to submit a Local File. The official language in Thailand is Thai. Documents to be submitted by the taxpayer to the Revenue Department should, strictly speaking, be in Thai. However, in practice, taxpayers may prepare and submit their transfer pricing documentation in English. The Revenue officer may nevertheless request that the taxpayer translate part or all of its transfer pricing documentation into Thai.
The Local File requirement applies to taxpayers with an annual revenue of more than THB 200 million. The Local File is effective for accounting periods beginning on or after 1 January 2019. The Local File must be filed within 60 days upon request by Revenue officers, except for the first request whereby the time is extended to 180 days.
The maximum penalty is THB 200,000 in case of failure to disclose or disclosure of incomplete or incorrect transfer pricing information on the Local File.
In June 2017, Thailand joined the Base Erosion and Profit Shifting Inclusive Framework (BEPS IF) which allows interested countries and jurisdictions to work with OECD and G20 members on developing standards on BEPS-related issues and reviewing and monitoring the implementation of the whole BEPS package.
Thailand was first reviewed under the phase-1 peer review process, wherein three recommendations were made. The phase I peer review report recommended
15+ years, experience in Global Databases and Benchmarking, Transfer Pricing Documentation & Compliance, Valuation, Policy, Research and Analysis.
Worked with PwC & Deloitte Global Transfer Pricing Centre. Enriched experience in Deloitte wherein was responsible for TP Compliance & Database Management, Valuation Support, Research and Advisory services for clients from varied industries.