Transfer Pricing Rules and Regulations in Thailand >>>
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1.Related Company which has income exceeding 200 million baht per accounting period must submit Disclosure Form which is form open an information about name of related company, income from business carried on, other income, purchase of materials/inventories, purchase of property plant and equipment, royalty, management fee, technical service fee, commission fee, balance of loan at the end of accounting period, balance of lending at the end of accounting period between related company.
2.Related Company has to prepare the master file or local file which file will open an information about related company structure such as shareholder, operation, marketing, business strategy, methods of transfer pricing of company group etc.
3.The key of transfer pricing for the master file or local, I think it is transfer pricing methods which have five methods and one special methods.
(1) Comparable uncontrolled price (CUP) method
(2) Resale price method (RP)
(3) Cost plus method (CP)
(4) Transactional net margin method (TNMM)
(5) Transactional profit split method (TPSM)
Other methods approved by Director-General of the Revenue Department (special methods, if cannot use CUP, RP, CP, TNMM or TPSM methods)
Transfer pricing should be selected and calculated when a transaction occurs or is about to occur, not after the transaction has already occurred. The company should has in-house transfer pricing team.
If your company understands the rules and regulations of transfer pricing, there's no need to further study for penalty and or surcharges.
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