In the past decade, transfer pricing has played an important role in the Asia Pacific region. Thailand is no exception. The management of a multinational company with a subsidiary in Thailand or planning to establish one, should know how to manage transfer pricing risk in Thailand, explain Sorraya Boonsongprasert and Tatpicha Pipatmongkolchai of HNP Counsellors – Taxand Thailand
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While the manual should be consulted for any questions around MAPs, the OECD’s Sriram Govind also emphasised that the guidance is ‘not a political commitment’
The landmark Indian Supreme Court judgment redefines GAAR, JAAR and treaty safeguards, rejects protections for indirect transfers and tightens conditions for Mauritius‑based investors claiming DTAA relief
As tax teams face pressure from complex rules and manual processes, adopting clear ownership, clean data and adaptable technology is essential, writes Russell Gammon, chief innovation officer at Tax Systems