Law firmBangkokEnglish · Thai · German
YOUR ONE-STOP COORDINATOR FOR INTEGRATED LEGAL, TAX AND BUSINESS SOLUTIONS
Service guide
Transfer Pricing in Thailand.
Who must file Thailand's transfer pricing disclosure form, what documentation the Revenue Department can demand, and what a TP engagement with a firm covers.
2 firms on Justenda. Compare firms
Key facts
- Who must file the disclosure form?
- Companies and juristic partnerships with related parties, unless their income for the period sits below the ministerial threshold, which the Revenue Code floors at 200 million baht. In practice the obligation starts at 200 million baht of annual income.
- When is the disclosure form due?
- With the annual corporate income tax return, within 150 days of the close of the accounting period.
- Can the Revenue Department demand more than the form?
- Yes. Within five years of the disclosure filing, assessment officers can request the documents behind the numbers, and they can adjust income and expenses that do not match independent-party terms.
Transfer pricing, done properly.
Talk to someone who does this every week. Verified firms reply with how they would handle your case and what it costs. Free, no account needed.
Transfer pricing in Thailand: what the rules require
Transfer pricing in Thailand is about the prices related companies charge each other. When a Thai company buys, sells, borrows, or licenses within its own group, the Revenue Code expects the terms to match what independent companies would have agreed. Assessment officers have the power under Section 71 bis to adjust a company's income and expenses when related-party terms differ from independent-party terms, which can mean more taxable profit and a larger tax bill after the fact.
The reporting side sits in Section 71 ter. A company or juristic partnership with related parties must file an annual disclosure form describing those relationships and the total value of related-party transactions. The law exempts only smaller companies below a ministerial threshold that the Revenue Code itself floors at 200 million baht of income for the accounting period, so in practice the obligation starts at 200 million baht. The form travels with the annual corporate income tax return, due within 150 days of the accounting period's close.
Filing the form is not the end of it. The Revenue Department can come back and request the supporting documents behind the numbers within five years of the filing, which is why the disclosure form and transfer pricing documentation are best treated as one piece of work rather than two.
The two transfer pricing obligations
Both flow from Section 71 ter of the Revenue Code. The disclosure form is filed every year; the documentation is produced when the Revenue Department asks for it, within five years of the filing.
| Disclosure form | TP documentation | |
|---|---|---|
| What it is | An annual form describing related parties and the aggregate value of transactions with them | The analysis and evidence showing related-party prices match independent-party terms |
| When it is due | With the annual corporate income tax return, within 150 days of the accounting period's close | On request from the Revenue Department, which can ask within five years of the disclosure filing |
| Who prepares it in practice | The company with its accountant or tax advisor, from the year's related-party ledger | A tax or transfer pricing firm, built on a functional analysis and benchmarking study |
- What it is
- Disclosure form: An annual form describing related parties and the aggregate value of transactions with them
- TP documentation: The analysis and evidence showing related-party prices match independent-party terms
- When it is due
- Disclosure form: With the annual corporate income tax return, within 150 days of the accounting period's close
- TP documentation: On request from the Revenue Department, which can ask within five years of the disclosure filing
- Who prepares it in practice
- Disclosure form: The company with its accountant or tax advisor, from the year's related-party ledger
- TP documentation: A tax or transfer pricing firm, built on a functional analysis and benchmarking study
Note: The arm's-length standard is the whole game
Every obligation on this page serves one test: would independent companies have agreed these prices? The Revenue Department's published transfer pricing framework rests on market-price assessment under the Revenue Code and sets out the pricing methods, the documentation it expects, and an Advance Pricing Arrangement route for companies that want certainty in advance. Documentation that cannot answer the market-price question is paperwork, not protection.
Your options
Contact experts who handle transfer pricing in Thailand
A first shortlist from 2 firms on Justenda. Compare them, then message one or several at once.
MSC International Law Office
Free consultation · 30 min
Law firmBangkokEnglish · Thai · Chinese (Mandarin) · Cantonese · Russian · German
International Legal and Cross-Border Business Advisory in Thailand and Asia
What a transfer pricing engagement covers
A typical engagement has three layers, and firms sell them separately or together. Benchmarking is the core: the firm analyses what your group companies actually do for each other, then searches databases of comparable independent companies to show your margins or prices sit inside an arm's-length range. Documentation wraps that study in the file the Revenue Department expects, covering the group structure, the transactions, the method chosen, and why. Audit support is the third layer: answering Revenue Department questions, defending the method, and handling an adjustment if one is proposed, work that overlaps with tax audit defense once a dispute is live.
Who needs this is mostly a function of size and structure. A foreign-owned subsidiary paying management fees, royalties, or interest to its parent is the classic case, and the same intra-group flows also carry withholding and treaty questions that sit with international tax compliance work. A purely domestic group above the threshold still files the disclosure form, because Section 71 ter does not care whether the related parties are Thai or foreign.
Pricing for this work is quoted per engagement. Firms scope it on the number of transaction types, whether a usable benchmarking study already exists for the region, and how far the documentation must go, so no honest fixed price exists to print here.
How a transfer pricing engagement typically runs
Map the related-party transactions
The firm identifies every intra-group flow: goods, services, management fees, royalties, loans, and guarantees. This map decides what must be disclosed, what needs a benchmarking study, and what can be left alone.
Run the functional analysis and benchmarking
For each material transaction, the firm documents who does what, who carries which risks, and which pricing method fits, then benchmarks the result against comparable independent companies.
Prepare the documentation and the disclosure form
The study becomes the transfer pricing documentation file, and the year's numbers feed the disclosure form filed with the annual return within the 150-day deadline.
Keep it alive and defend it if tested
Numbers move every year, so the file gets refreshed rather than rebuilt. If the Revenue Department requests documents within its five-year window or proposes an adjustment, the firm that built the file defends it.
When this work is worth paying for
The money at stake is rarely the filing itself. It is the adjustment risk: officers can rewrite related-party income and expenses to independent-party terms, and penalties apply for failing to file the disclosure form or filing it incomplete. A group above the 200 million baht line with cross-border charges to a parent is carrying real exposure if the file behind those charges is thin.
A firm can benchmark the prices before the Revenue Department tests them, build documentation that answers the market-price question, and stand behind it in an audit. Tax lawyers in Thailand and specialist TP practices inside accounting firms both do this work; what matters is that the same team owns the study and its defense.
This page is general information, not legal advice. Rules, thresholds, and procedures change; for a specific group structure, speak with a qualified professional.
Also listed
More firms that handle transfer pricing
Every one of these is verified on Justenda and can take on transfer pricing work in Thailand.
Law firmBangkokEnglish · Thai · German
YOUR ONE-STOP COORDINATOR FOR INTEGRATED LEGAL, TAX AND BUSINESS SOLUTIONS
MSC International Law Office
Free consultation · 30 min
Law firmBangkokEnglish · Thai · Chinese (Mandarin) · Cantonese · Russian · German
International Legal and Cross-Border Business Advisory in Thailand and Asia
Next step
Describe your case once.
Send one focused inquiry with your situation, timing, and preferred language. Firms reply with how they would handle it and what it costs, so you can compare answers instead of chasing quotes.
Common questions
Frequently asked questions
- What is the transfer pricing disclosure form in Thailand?
- It is an annual report under Section 71 ter of the Revenue Code in which a company or juristic partnership describes its related parties and the total value of transactions with them. It is filed together with the annual corporate income tax return, within 150 days of the close of the accounting period, and applies to companies with related parties whose annual income reaches the 200 million baht threshold.
- What counts as transfer pricing documentation?
- Documentation is the file that shows related-party prices match what independent companies would have agreed: the group structure, the transactions, a functional analysis of who does what and carries which risks, the pricing method chosen, and a benchmarking study against comparable independent companies. The Revenue Department can request it within five years of the disclosure form's filing, so most firms prepare it alongside the form rather than waiting for a request.
- Does transfer pricing only apply to foreign-owned companies?
- No. Section 71 ter applies to related companies and juristic partnerships whether the related parties are Thai or foreign, so a purely domestic group above the income threshold still files the disclosure form. Cross-border groups simply carry more of the adjustment risk, because payments such as management fees, royalties, and interest to a foreign parent are the transactions the arm's-length test most often reaches.
- What does a transfer pricing engagement cost in Thailand?
- There is no official fee schedule, and firms quote per engagement rather than from a price list. The scope drivers are the number of related-party transaction types, whether a usable benchmarking study already exists, and whether the engagement is documentation only or includes audit support. A firm will quote after seeing the group structure and the year's related-party flows.
All firms
Every firm that can help you with transfer pricing
Law firmBangkokEnglish · Thai · German
YOUR ONE-STOP COORDINATOR FOR INTEGRATED LEGAL, TAX AND BUSINESS SOLUTIONS
MSC International Law Office
Free consultation · 30 min
Law firmBangkokEnglish · Thai · Chinese (Mandarin) · Cantonese · Russian · German
International Legal and Cross-Border Business Advisory in Thailand and Asia
Guides & Insights
Practical explainers on this topic: general information, not professional advice.
Tax & Accounting
Tax Identification Number in Thailand: How to Get a Thai TIN
A Thai national's ID card number is already their tax ID, and a company's DBD registration number is already its own. Who still has to apply, on which form, and inside which 60 days.
Tax & Accounting
How to File a Tax Return in Thailand: PND 90 and PND 91
Filing is triggered by how much you earned, whether or not any tax is due. Which form applies, the March and April deadlines, online versus paper, paying, refunds, and what late filing costs.
Tax & Accounting
Thailand Tax Residency and Income Tax for Foreigners
Thailand tax residency turns on 180 days in a calendar year, not on your visa. What that means for Thai income, foreign income, deductions and the rate you pay.
In this practice area