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Thailand deliberates transfer pricing law

Thailand’s Council of State is deliberating the country’s first law on transfer pricing. If passed the bill would allow Thailand Revenue Department (TRD) officials to enquire into profits from cross-border transactions of multinational companies.

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 effected ,” said Benjamas Kullakattimas, tax partner at KPMG in Thailand. “If the law is issued this year though, it is possible the TRD will want the taxpayer to start providing transfer pricing documentation from the 2015 tax year, due May 30 2016.”

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