Thailand Transfer Pricing Policy

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Manager Paul, Speak in Thailandese English
WeChat: Paul0864580532

TP-Q-10
Why kinds of scenarios will be adopted TP policy? What is the relevance of DTA and TP policy?

TP-A-10
When Thailand Tax entity would like to pay out whatever business profits, Royalty, Technical Services fees, Interests, trading amount etc., it will adopt DTA tax rate. Its judge criteria, please see the Thailand Treaty Page.
But if want to verify the above-mentioned amount if reasonable, will adopt Thailand TP Policy.

TP-Q-20:
在泰國甚麼情況下, WFOE 外商投資企業不需要同時處理TP 申報和文件申報?
What are the scenarios in Thailand, that a Wholly Foreign-Owned Entity (WFOE) is exempted from compliance of Transfer Pricing (TP) declaration and TP documentation?

TP-A-20:
Taxpayers with an annual turnover of less than Baht 200 million are exempted from preparing TP declaration and TP documentation.

TP-Q-30:
在泰國甚麼情況下, WFOE 外商投資企業需要向該國的稅務局發送TP 申報? 甚麼是申報單名稱?
What are the scenarios in Thailand, that a Wholly Foreign-Owned Entity (WFOE) is required to submit TP declaration to the country’s tax bureau?
What is the name of the TP declaration form?

TP-A-30:
Taxpayers with an annual turnover of Baht 200 million or more are required to make a mandatory TP declaration form namely TP disclosure form.

TP-Q-40:
在泰國甚麼情況下, WFOE 外商投資企業需要向該國稅務局發送TP 申請和文件? 甚麼 declaration 表單名和文檔名?
What are the scenarios in Thailand, that a Wholly Foreign-Owned Entity (WFOE) is required to submit TP declaration and TP documentation to the country’s tax bureau? What is the name of the TP declaration form and TP documentation form?

TP-A-40:
Taxpayers with an annual turnover of Baht 200 million or more are required to make mandatory transfer pricing reporting.
TP declaration form – TP disclosure form
TP documentation – Local File, Master File and Country-by-Country (CbC) Report.

Thailand TRANSFER PRICING for professionals

Overview
In general, transfer pricing rules in Thailand are generally based on the OECD Transfer Pricing Guidelines.
The transfer pricing laws apply to both cross-border and domestic related party transactions.
Taxpayers with an annual turnover of Baht 200 million or more are required to make mandatory transfer pricing reporting.

Related party
Persons failing under the below are considered as related parties:
*Direct or indirect shareholding of at least 50% on another.
*Having common shareholding of at least 50% on another.
*Having control over capital, management of another so that one cannot operate independently from the other.

Acceptable Transfer Pricing method

*Comparable Uncontrolled Price (CUP)

*Resale price

*Cost-plus

*Profit split

*Transactional net margin

Due dates and respective threshold:

Please be aware of below Warning:
The above contents are digested by Evershine R&D  and Education Center in October 2021.
Regulations might be changed as time goes forward and different scenarios will adopt different options.
Before choosing options, please contact us or consult with your trusted professionals in this area.

Contact Us

Bangkok Evershine BPO Service Limited Corp.
Email: bkk4ww@evershinecpa.com
Manager Paul, Speak in Thailandese English
WeChat: Paul0864580532

or
For investment structure relevant to multi-national tax planning and Financial & Legal Due Diligence for M&A (Merge and Acquisition), send an email to HQ4bkk@evershinecpa.com
Dale Chen, Principal Partner/CPA in Taiwan+China+UK will be accountable to your case.
LinkedIn address:Dale Chen

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(version: 2024/07)

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