Align your Thai operations with the Revenue Department's stringent Section 71 requirements. Manage Disclosure Forms (TPDF), Local Files, and CbC reporting with local expertise.
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Transfer pricing in Thailand is governed by the Revenue Code Amendment Act (No. 47) and specifically **Sections 71 bis and 71 ter**. The Thai Revenue Department (TRD) utilizes a mandatory Disclosure Form as a primary risk assessment tool to identify audit targets.
Under current regulations, taxpayers must maintain contemporaneous documentation that justifies the arm's length nature of their transactions. While smaller entities may be exempt from filing, the TRD retains the power to adjust income and expenses for any non-arm's length related-party dealings.
Mandatory for entities exceeding THB 200 million revenue. Must be filed within 150 days of the fiscal year-end alongside Form PND 50.
Grants tax officers the power to request full TP documentation, which must be submitted within 60 days of the request (or 180 days for first-time requests).
A fixed penalty for failure to submit the disclosure form or for providing inaccurate/incomplete information without justifiable grounds.
The mandatory filing trigger for Thai entities.
Submission of the Transfer Pricing Disclosure Form (TPDF) is required if:
• Annual total revenue ≥ THB 200 Million.
This includes all related party transactions regardless of value once the total revenue threshold is met.
Specific formatting rules for Thai documentation.
The Local File must be prepared in the Thai Language. While English versions are often maintained by MNEs, a formal Thai translation is mandatory for submission to the TRD.
Benchmarking studies are typically required to be updated every three years, provided there are no significant changes in the business.
Threshold for groups over THB 28 Billion.
MNE groups with consolidated revenue ≥ THB 28 Billion (approx. EUR 750M) must file. A notification must be submitted through the TPDF (Part C).
The full CbC report is due within 12 months after the last day of the MNE group's fiscal year.
Accurate filing of the mandatory disclosure form to minimize audit risk.
Drafting compliant documentation in Thai as per Notification No. 407.
Economic analysis focusing on SET-listed and local Thai comparables.
Strategic representation and response management during tax investigations.
The Revenue Department is actively using TPDF data for audit selection. Ensure your defense is ready before the request arrives.
Contact Bangkok TeamFor further information on transfer pricing please contact:
Leader - TP Policy
Leader - Global Databases & Benchmarking