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Transfer Pricing update 2022

Narumol Limprasert Narumol Limprasert

New Transfer Pricing Disclosure Form


This tax news will be of interest to: Thai tax entities with a total annual revenue of more than THB 200 million, which have also had transactions with related companies.


This is to apprise you regarding the new Transfer Pricing Disclosure Form (DF) which has been issued by the Thailand Revenue Department (TRD). Please see this direct link to the form for your reference.


Apart from the English translation provided by the TRD in the new DF, there are now additional questions in Part C – Other Information related to the Country-by-Country Report (CbCR) notification. These questions involve clarifying whether the Thai reporting entity is a part of a multinational companies (MNC) or juristic partnership group which is obliged to file the CbCR. If yes, the Thai reporting entity needs to specify the filing company name and the jurisdiction/country for the MNC or the group when reporting to the TRD.


Furthermore, the requirement to provide information about the impact of business restructuring between the Thai reporting entity and related companies on the revenue, cost, or gross margin of the reporting entity has been deleted from the new DF.


Our notable points

The newly issued DF requires that Thai reporting entities provide a notification to the TRD with respect to the Country-by Country reporting regulation (Director-General Notification No. 408, issued by the TRD on 30th September 2021), as this regulation is effective from the accounting period beginning on or after 1 January 2021.


For further questions, please contact: Narumol Limprasert – Tax Partner (Transfer Pricing) at or +66 2 205 8222.