The final draft of the law was approved by the Cabinet in May this year. It was created in line with OECD guidelines.
Thailand has no specific anti-avoidance legislation. The only provision in place is a Departmental Instruction (No.Paw 113/2002), which states that a company operating in Thailand must calculate its net profit for corporate tax in accordance with section 65 of the Thai Revenue Code.
The new law would require companies to provide transfer pricing documentation to the TRD within 150 days after the end of the accounting period. Failure to do would result in a penalty of up to Bt400,000 ($12,000).
“We cannot now say what date the law will be