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March 1, 2021
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Thailand requires transfer pricing disclosures to be filed online

The Director-General of Thailand’s Revenue Department has issued a notice making it mandatory for companies to submit their transfer pricing disclosure forms online unless they have reasonable grounds for filing a paper form.

The notification, issued on 14 January,  is effective for accounting periods commencing on or after 1 January 2020. 

Many companies in Thailand adopt a 31 December year-end and will need to follow the notification when filing a disclosure form for the 31 December 2020 year.

Only companies with Baht 200 million (USD 6.7M) or more in revenues in an accounting period must file the disclosure form with the Thailand revenue department, disclosing details of their transactions during the year with related parties.

Companies must register to submit the form online. Registration and filing of the form must be done through the Thailand revenue department’s website, either directly or via the Ministry of Finance’s “Tax Single Sign-On” system.

The form will be considered submitted when the taxpayer receives a reference number from the online filing system.

If a disclosure form is filed by paper it must be accompanied by a letter explaining the reasons why the company cannot submit the form online.

Compulsory online filing of transfer pricing forms will greatly enhance the Thailand revenue department’s ability to review and analyse the information disclosed in the forms and assist in selecting taxpayers for transfer pricing audits.

The official notification is available in the Thai language

Paul Ashburn, Co-Managing Partner and international tax specialist, HLB Thailand
Paul is an international tax specialist at HLB Thailand, with more than 20 years of experience providing advice on Thai and international tax to foreign businesses. HLB Thailand is a member of Network of the Year 2020, HLB International – a global network of independent professional accounting firms and business advisers.”. Email: paul.a@hlbthailand.com
Rohit Sharma, Principal – Transfer Pricing, HLB Thailand
Rohit is an MBA, Finance from the Institute of Chartered Financial Analysts of India, Business School (IBS), Chandigarh, and holds a bachelor’s degree in Commerce from Delhi University. He is a Senior Manager in the transfer pricing department. Rohit is a Principal, transfer pricing with HLB Thailand based in Bangkok. Rohit has 8+ years of experience in transfer pricing across India, Malaysia, and the Philippines. Rohit specializes in transfer pricing engagements for a large range of domestic and multinational clients. Previously, Rohit was engaged in advising clients on various transfer pricing issues, policies, planning, dispute resolution, and documentation, etc. Leveraging on his experience and knowledge, coupled with his strong client relationship, networking, negotiation, and team management skills, he is focused on client service excellence and developing new opportunities for the firm. Rohit’s transfer pricing experience includes: • Transfer pricing policy planning • Transfer pricing documentation/compliance • BEPS Action Plan (CbCR, Master-file) • Due-diligence • Accountant’s report/ TP disclosure • Undertaking BEPS impact analysis • Defense strategies for transfer pricing assessments and litigation • Advance pricing arrangements, etc. Email: rohit.s@hlbthailand.com Mobile : +66 6 2714 0577
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