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Transfer Pricing Disclosure Requirements

 

Transfer Pricing Disclosure Requirements

The Notification of Director-General of TRD on Official Transfer Pricing (“TP”) has been released on 7th November 2019. Thai corporate taxpayers with revenue of at least THB200 million are required to provide information regarding their related-party relationships and the value of related party transactions on the Disclosure Form. The form must be submitted by 150 days following the year-end. The penalty for not filing or reporting incorrect information is 200,000 Baht, the business owners must consider their company’s filing requirements carefully.

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The related parties” Under section 71 bis of the Revenue Code means:

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  • The company holds shares in another entity, directly or indirectly of at least 50% of that entity’s total share capital.
  • The same shareholder holds shares in each entity, directly or indirectly of at least 50% of the total share capital.
  • The entity that is related in terms of capital, management, or control that makes one entity unable to operate independently of the other as prescribed by ministerial regulation.

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