Article
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...
Article
The Director-General of the Revenue Department has issued a notification clarifying the transfer pricing documentation that taxpayers should maintain.
Article
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...
Article
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.
Article
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’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 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...
Insight
The OECD first created the Base Erosion and Profit-Shifting (BEPS) action plan in 2016. Guidelines were initially adopted by 82 countries. Today, over 140 countries operate in line with the...
Article
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
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.
