Online filing of Transfer Pricing disclosure forms now mandatory
HLB Thailand Transfer Pricing Team
The Director-General of the Revenue Department has issued a notification requiring companies to submit their Transfer Pricing Disclosure Form electronically, unless there are reasonable grounds for filing in paper form.
The notification was issued on 14 January and applies to accounting periods commencing on or after 1 January 2020. As many companies in Thailand adopt a 31 December year end, the requirement applies to disclosure forms filed for the year ended 31 December 2020 onward.
The disclosure form requirement applies to companies with annual revenues of Baht 200 million (approximately USD 6.7 million) or more in an accounting period. Eligible companies must disclose information on their related parties and related-party transactions conducted during the year.
Moreover, following Revenue Department Notification No. 408 dated 30 September 2021, Thai entities subject to Country-by-Country Reporting (CbCR) requirements are required to provide their CbCR notification in Part C of the Transfer Pricing Disclosure Form. This requirement applies to accounting periods commencing on or after 1 January 2021.
Companies are required to register before submitting the disclosure form electronically. Registration and filing must be completed through the Revenue Department’s website, either directly or via the Ministry of Finance’s Tax Single Sign-On (SSO) system. The form is deemed successfully submitted once a reference number is generated by the online filing system.
If a company files the disclosure form in paper format, it must submit an accompanying letter explaining the reasons why online filing is not possible.
It is expected that the move to mandatory electronic filing has significantly enhanced the Revenue Department’s ability to review and analyse transfer pricing information, and to support a more targeted and efficient selection of taxpayers for transfer pricing audits.
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