On 3 January 2018, the Thai Cabinet approved the draft specific transfer pricing legislative provisions after public consultation during 2017. Taxpayers with international and domestic related party transactions should consider whether to expedite any transfer pricing analysis, comparable search and transfer pricing documentation in view of the mandatory reporting and whether the THB 30M minimum annual turnover threshold applies (and whether that threshold is amended by the Minister of Finance which sets a higher threshold) as well as any amendments or potential delays. Note that documents or evidence from the reported position can be requested for the previous 5 years from the submission of the report through the new legislation.
These regulations shall apply to accounting periods starting from or after 1 January 2017 onwards.
The draft specific transfer pricing legislative provisions are as follows: