Insight

Which Southeast Asian Nations Have Adopted the OECD BEPS Action Plan 13?

Insight

OECD Guidelines for Transfer Pricing during the COVID-19 Pandemic in Thailand

Taxpayers and tax administrators around the world are grappling with the unprecedented impact the COVID-19 pandemic is having on transfer pricing arrangements. On 18 December 2020, the OECD published the...

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Transfer Pricing documentation and adjustment rules clarified

The Director-General of the Revenue Department has issued a notification clarifying the transfer pricing documentation that taxpayers should maintain.  

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Online filing of Transfer Pricing disclosure forms now mandatory

The Director-General of the Revenue Department has issued a notification making it mandatory for companies to submit their transfer pricing disclosure forms online unless they have reasonable grounds for filing...

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Thailand’s new Transfer Pricing law: Assessing the risks for taxpayers

Paul Ashburn and Rohit Sharma of HLB Thailand explore how Thai transfer pricing legislation has evolved to entail greater disclosure requirements and discusses the associated risks for taxpayers.

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How Country-by-country reporting (CbCR) regulations are evolving in Thailand

Andrew Jackomos and Rohit Sharma of HLB Thailand assess how country-by-country reporting (CbCR) regulations are evolving in Thailand, and consider the implications for businesses.

Insight

Thailand clarifies rules for use of internal and external comparables

Thailand’s Ministry of Finance has issued a Ministerial Regulation under the Revenue Code prescribing the approach Thai tax officers should take when analysing and adjusting the pricing of transactions between...

Insight

The impact of COVID-19 on your Transfer Pricing arrangements

The COVID-19 pandemic has had an abrupt impact on the world’s economy. A year of economic development has been turned on its head as whole countries lockdown in a bid...

Article

What’s the difference between a Master file and a Local file?

Under Chapter V of the 2017 OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, a three-tiered approach to Transfer Pricing documentation has been incorporated for taxpayers with related...

Insight

Year-end transfer pricing adjustments and customs valuations

It’s hardly unusual for subsidiaries of multinational groups to find that their actual operating results aren’t aligned with the arm’s-length principle at the end of the year.

Insight

Everything you’ve ever wanted to know about Transfer Pricing in Thailand (with examples)