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Preliminary comments on the new draft of Thailand Transfer Pricing Law H&P Tax law firm in Bangkok Tax advisers

The draft of Transfer Pricing Law was approved by the Cabinet of Thailand on January 3rd, 2018.

On June the 5th this draft has been submitted to National Legislative Assembly for consideration and expected to be in force on or after January 1st, 2019, meaning that the law may be officially adopted this year.
Transfer pricing draft is aiming to tackle tax avoidance issue and create regulation for taxpayers who anticipate to make or have been making transaction between other parties within the scope of transfer pricing.
According to the draft law, any taxpayers with minimum income of THB 30 million will be exempt from submission of document explaining relation between party transactions called “transfer pricing disclosure form”.

As a result, taxpayers having income worth more than THB 30 million are liable to prepare and submit transfer pricing documentation. The revenue officer is allowed to request related evidence or document supporting transfer pricing transaction within 5 years from the date of the transfer pricing disclosure form submission.

Moreover, taxpayers who pass minimum income threshold are subject to submit annual report revealing relationship between related party transactions. Even though such relationship may not last for the whole accounting period.

If you require professional advice on Transfer Price or Corporate Income Tax in Thailand, please contact our Bangkok lawyers at [email protected]

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