Transfer Pricing Services
Transfer Pricing relates to the price non-arm’s length entities located in different jurisdictions charge each other for goods and services. The tax rules related to transfer pricing are complex and governments are increasingly proactive in scrutinising transfer pricing policies and practices. Government audits of transfer pricing activities can be time-consuming and stressful, and the penalties for running afoul of transfer pricing rules can be significant.
Countries all over the world are applying greater scrutiny – and calling for stricter regulations – on transfer pricing practices. However, this greater scrutiny can provide an opportunity to identify more cost-effective arrangements for your international transactions.
In Thailand, all companies need to make sure that their related party pricing is arm’s length and is supported by transfer pricing documentation. Failure to have adequate transfer pricing documentation can result in high tax penalties in the event of a tax audit.
At a global level, there has been a rapid introduction and increasing enforcement of transfer pricing regulations, spurred on by the Organisation for Economic Cooperation and Development (OECD), as part of their Base Erosion and Profit Shifting Initiative (BEPS). This is having a substantial impact on current and future transfer pricing structures for businesses of all sizes trading internationally.
HLB Thailand helps corporate groups navigate this fast-changing transfer pricing environment. Aided by dedicated transfer pricing practitioners around the HLB network, we provide a range of planning, compliance, audit defence and benchmarking services. We can work with you to develop transfer pricing policies that are defensible, flexible and in line with your overall tax planning strategies.
In 2025, ITR World Tax rankings for Transfer Pricing announced that HLB Thailand have been ranked as one of the best performing TP firms five years in a row and additionally we have been ranked “Notable Firm” in General Corporate Tax category by ITR’s 2026 World Tax. Read more here.
Learn more about our
Transfer Pricing services
Our Expertise
Documents Preparation
We create thorough Transfer Pricing documents to ensure regulatory compliance.
Optimal Structures
Designing ideal Transfer Pricing structures based on your value chain and key operational factors.
Audit Support
We assist during tax audits, offering practical advice and representing you with tax authorities.
Advanced Pricing Agreement (APA)
Obtain APAs for pricing certainty, reducing the risk of disputes.
Efficient Tax Response
Expertise in handling tax authority inquiries, ensuring smooth processes and favourable outcomes.
Compliance Guidance
Assisting clients in navigating transfer pricing complexities for efficient tax compliance.
HLB Thailand specializes in a wide range of services, including audit, tax, legal, outsourced CFO, accounting and internal audit services for businesses operating in Thailand. Our team of experienced professionals is at your disposal to help you achieve your business objectives in the most cost-effective manner. Our team of specialists come from diverse business backgrounds such as finance, accounting, legal and operations.
Client Testimonials
" We were pleased with the prompt and thorough assistance provided by HLB Thailand in assisting our Australian client with their Thai transfer pricing obligations.
This is very true, we are grateful for your assistance in this regard. We enjoyed working with you and hope to have more projects together in the future!"
Dritton - Founder & Director
Client's Testimonials
"The TP report of Docquity Thailand has come up quite nicely. The report has captured all the necessary factual detailing and information typically required from the transfer pricing perspective. Especially the ‘Functional, Assets and Risks analysis’ which was delineated in a comprehensive manner and covered every significant business & commercial aspect pertaining to all related party transactions of the Company.
Keep up the good work and wishing you the very best.
We, Docquity Group, look forward to strengthening our relationship with HLB Thailand"
Amar - Docquity Transfer Pricing Head
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