Transfer pricing is a 'soft target' for tax authorities as there is no absolute rule for determining the 'right' transfer price.
The Thailand Revenue Department issued Departmental Instruction No. Paw 113/2545 (D.I. No. Paw 113/2545) in May 2012 which requires all companies with inter-company transactions to prepare and maintain current transfer pricing documentation at their office. On 23 April 2010, the Revenue Department issued the Thailand APA Guidelines.
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 dedicated Transfer Pricing Team will work with you to develop an overall comprehensive transfer pricing strategy.