Transfer Pricing | Mazars | Thailand

A global view on a business-critical, fast-evolving issue.

Transfer pricing (“TP”) in Thailand plays a major role in every company with cross-border activities, including intra-group supply and service relationships and financial integration, as well group restructuring.

While the tax audit risks associated with transfer prices can be significant, there is also an opportunity for the tax-efficient structuring of transactions.

In order to help clients assess the risks adequately and utilise all possibilities for optimisation, Mazars’ experts perform case studies of each situation involving transfer pricing and consider not only the Thai regulations, but the transfer pricing rules and regulations in the other countries involved as well. This is possible because Mazars can draw on the expertise of over 44,000 professionals in over 90 countries, and thus offer seamless cross-border support in all of the areas below related to transfer pricing:

• TP reports and benchmarking studies
• TP policy implementation
• TP planning and structuring
• TP compliance and documentation
• Tax advisory services on specific TP issues
• Support with tax audits related to TP issues
• Justifying the transfer prices used to the tax authorities in the course of a tax audit

Organisations that span international borders are increasingly facing complex regulatory and tax issues in the different jurisdictions where they operate. Transfer pricing is at the top of the tax priority list for many mid-sized and large businesses, with an outsized impact on business units. We offer a range of tax advisory services for transfer pricing management so you can be ensured of compliance with local and OECD regulations in Thailand.

OECD regulations require any multinational company doing business in several countries to maintain a transfer pricing master file, a local file, and a country-by-country report.

The transfer pricing master file is prepared by the parent company and serves as an overview of the company’s interbranch financial transactions. In addition, the master file contains descriptions of the company’s global business activities, geographical locations, global supply chain, and individual branch business activities.

The transfer pricing local file goes into more detail about the business activities of each branch of the company. It’s the document filed with the local tax authorities and determines the local tax liability for an individual branch.

The country-by-country report offers an ongoing report of revenues, profits and local taxes paid by a regional branch of the company.

Mazars offers expert global transfer pricing services in Thailand to companies that need to establish and maintain this required three-tiered approach to OECD regulations.