The Ministry of Finance in June 2019 submitted to the Thai Cabinet a draft ministerial regulation concerning information required for transfer pricing documentation submissions. The draft ministerial regulation would be intended to implement measures under Thailand’s transfer pricing law (finalized in 2018).
As proposed, the transfer pricing documentation-related guidance would provide as follows:
Tax professionals have observed that the draft regulatory guidance is consistent with the Thai Revenue Department’s move to implement the OECD’s transfer pricing guidelines in Thailand. Multinational entities investing in Thailand and Thai corporations entering into related-party transactions and with income exceeding Baht 200 million will want to consider preparing appropriate transfer pricing analysis and documentation.
Read a July 2019 report prepared by the KPMG member firm in Thailand
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