Transfer pricing
On June 2, 2017, Thailand joined the “Base Erosion and Profit Shifting Inclusive Framework” (“BEPS”) and committed to implementing the minimum standards of BEPS. Accordingly, Thailand’s “Amendment Act on Transfer Pricing Issues in the Tax Code” (referred to as the “Transfer Pricing Law”) was announced on November 18, 2018, and took effect on January 1, 2019, requiring any company with an annual revenue of more than 200 million baht (about 40 million yuan) to submit an affiliated transaction information disclosure form when making an annual tax return. In the past year, in practice, we have seen many transfer pricing problems of enterprises in Thailand, such as: lack of a sound transfer pricing management system and structure; enterprises have no understanding and attention to whether they need to submit an affiliated transaction information disclosure form, whether they need to submit a country by country report, etc.; management has not fully realized the importance of transfer pricing arrangements and the possible impacts; lack of sensitivity to transfer pricing risks and failure to establish risk pre plans in advance for potential risks. Based on this, according to international standards, we provide assistance and advice to companies engaged in international transactions or domestic transactions with their affiliated enterprises. Our transfer pricing services include: transfer pricing advice, transfer pricing setting, transfer pricing risk assessment, transfer pricing affiliated transaction declaration form and local document preparation, price benchmark analysis, advance pricing arrangements; transfer pricing document compilation such as disclosure forms, Thailand local documents and country by country reports; advance pricing arrangements and mutual agreement procedures.