New Transfer Pricing Regulations

At the Cabinet meeting on 7 May 2015, the Cabinet approved a draft bill to amend the Revenue Code which will add a provision to define the criteria for determining the transfer price between controlled or related entities.

Keywords: Mazars, Thailand, Tax, Revenue Code, Revenue Department, Transfer Pricing

18 June 2015

With this amendment, the Revenue Department will have the power to adjust the taxable income and expenditure of controlled or related entities which have entered into transactions that are not on an arm’s length basis. In addition, related entities will also be required to submit transfer pricing documentation declaring direct or indirect relationship in capital, management or control among its group as well as the calculation method of inter entity revenue and expenditure to the Revenue Department within 150 days from the closing date of the accounting period.

It should be noted that this draft Transfer Pricing legislation has yet to be considered and approved by the National Legislation Assembly in order to become effective as a law.

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