Transfer pricing remains a key priority for multinational companies.

Our Transfer Pricing services offer effective solutions to companies undertaking international transactions or domestic transactions with its associated enterprises. We assist in planning, policy making, deciding whether to obtain an Advanced Pricing Agreement, implementation and documentation.

Transfer pricing planning

Determination of transfer pricing policy is the safest approach that brings certainty to related party transactions and mitigates tax exposure in advance. Prior to commencing any international transactions or even domestic transactions with its associated enterprises, it is essential that the transaction is evaluated, structured and planned to ensure that the transfer pricing implications are addressed.  

Our approach includes the following:

  • Supply chain re-engineering
  • Structuring cross-border related party transactions
  • Economic analysis
  • Preparation of inter-company agreements
  • Documentation

Transfer pricing documentation

The burden of demonstrating the arm’s length nature of international related-party transactions is on the taxpayer. Our transfer pricing services include the following:

  • Identification of intercompany and associated enterprises transactions
  • Analysis of functions, assets and risks (FAR)
  • Categorizing the economic relationships between each entity and their respective functions
  • Economic analysis / comparability analysis
  • Documentation
  • Drafting of the relevant agreements between and among the associated enterprises (with the assistance of the relevant GT offices overseas)

Advance pricing agreements

In order to obtain an advance pricing agreement (APA) with the Thai Revenue Department we will do the following:

  • Assist in: carrying out a cost benefit analysis; identifying the advantages and disadvantages of obtaining an APA; and determining the type of APA to obtain
  • Preparation and assistance in informal discussions with the tax authorities regarding the APA
  • Preparing the APA application – bi-lateral or multilateral (with the assistance from our relevant overseas offices)
  • Assistance in coordinating, preparing additional submissions and in negotiating the terms of the APA with the tax authorities
  • Post APA services

Edward Strauss

edward.strauss@th.gt.com