Thailand: Cabinet approves transfer pricing measures | KPMG Global
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Thailand: Cabinet approves transfer pricing measures, with amendments

Thailand: Cabinet approves transfer pricing measures

The Cabinet of Thailand on 3 January 2018 approved a draft transfer pricing law.


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The draft transfer pricing law was revised to include the following additional requirements.

  • The minimum income threshold for taxpayers to be eligible for being exempt from having to prepare a report on the relationship between companies and the amount of related-party transactions (collectively referred to as transfer pricing disclosure form) would be not less than 30 million baht for the accounting period. The government may announce more details in a future ministerial regulation.
  • The new transfer pricing law would apply for accounting periods beginning on or after 1 January 2017, so that the first filing date for the transfer pricing disclosure form would be 31 May 2018 (for the period 1 January - 31 December 2017).
  • The statutory limitations period for a tax officer to request for a related company to submit information and evidence of information needed for analyzing the transactions of a related company—also known as transfer pricing documentation—is five years from the date of submission of transfer pricing disclosure form.

The next step is for the draft transfer pricing law to be submitted to the national assembly legislature for consideration.


Read a January 2018 report prepared by the KPMG member firm in Thailand

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