Thailand Transfer Pricing Law Enacted

Global Tax Update : November 2018 / Thailand

The transfer pricing law, which was approved by the National Legislative Assembly in September 2018, was enacted and published in the Royal Gazette on 21 November 2018.

The new law will be effective for accounting periods commencing on or after 1 January 2019.

We now await the issuance of the supporting Ministerial Regulations and Notifications of the Director-General of TRD which will provide more clarity on the application of the new law.

With the introduction of the transfer pricing law, taxpayers should ensure transfer pricing compliance. Well-prepared, contemporaneous transfer pricing documentation not only serves as an efficient tool in preparing the disclosure form to be submitted with the annual corporate tax return, but it could also put taxpayers in the better position to defend with the Revenue officers if and when the transfer pricing audit takes place; hence, reducing potential exposures and penalties.

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* This Article is based on the relevant Japanese or specific country’s tax law and other authorities in effect on the date of this Article. This Article would not be guaranteed updating if there are any changes in Japanese tax law, any other law, or interpretations by the courts or tax authorities thereof after the date of this Article.

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