Transfer Pricing Services

Section 71 bis of Thailand's Revenue Code empowers the tax authorities to adjust related-party pricing under the arm's length principle. Section 71 ter requires companies with annual revenue of THB 200 million or more that have related-party transactions to submit a related-party transaction disclosure form with their annual corporate income tax return (P.N.D.50), and to provide transfer pricing documentation within the prescribed deadline when requested by the Revenue Department (RD).

Missing documentation or inappropriate pricing can lead to tax adjustments, double taxation and penalties. Z&X provides transfer pricing services ranging from local file preparation and annual maintenance to group master files, so your pricing is well supported.

· Local file (first year): Identification of related-party transactions, functional and risk analysis, comparability analysis and preparation of the local file.

· Annual maintenance: Data updates, benchmark review, and updates to the local file and disclosure form.

· Group master file: Group organizational structure, transfer pricing policies and value chain, intangibles and financing arrangements.

· Disclosure form support: Assistance in completing the related-party transaction disclosure form filed with the P.N.D.50.

We perform comparability analysis using professional databases and work alongside our audit and tax teams to keep pricing conclusions consistent with tax filings and assurance work.

· Chinese businesses in Thailand with related-party transactions: Covering both cross-border and domestic transactions.

· Companies meeting the disclosure threshold: Required to file the disclosure form and prepare transfer pricing documentation.

· Chinese groups: Groups needing a master file and a unified group transfer pricing policy.

· Kick-off and scoping (within 1 week of engagement): Confirm scope, issue a document request list and assemble the project team.

· Information gathering and interviews (1–2 weeks after documents are complete): Mapping of related-party transactions, interviews and data collection.

· Functional, risk and comparability analysis: Functional and risk analysis, database searches and determination of the arm's length range.

· Documentation: Preparation of the local file / master file and recommendations for the disclosure form.

· Review and finalization (1–2 weeks after first draft): Partner review, independent review and sign-off by an equity partner, and final delivery.

A first-year local file takes around 6–10 weeks, subsequent years around 4–6 weeks, and a master file around 4–8 weeks. We recommend starting as soon as possible after the financial year-end to align with the P.N.D.50 filing deadline.

· Transfer pricing local file: Prepared in line with Thai requirements.

· Comparability analysis report: Comparable company search and arm's length range analysis.

· Group master file (if required): Covering group structure, value chain and transfer pricing policies.

· Disclosure form recommendations: Supporting the annual filing.

The related-party disclosure obligation and the local file obligation must be assessed separately. The exact scope of services is set out in the scope of work confirmation.

The Compliance Self-Check for Chinese-Invested Companies in Thailand covers 13 checks across six areas: shareholding structure, registered address and property, staff and employment, accounts and documents, BOI compliance, and tax filing. Each check comes with clear criteria, so you can see whether you are in the green, yellow or red zone and what to fix first.

Free download: Compliance Self-Check for Chinese-Invested Companies in Thailand (PDF, 3 pages)

Unsure about any item after the self-check? Book a transfer pricing consultation →

The following services can be combined with this one; see each page for details:

· Tax Health Check: tax-by-tax review of past filings with a risk list and remediation plan

· Global Minimum Tax (Pillar Two): effective tax rate calculation and top-up tax filing for Thai entities of large groups

· How should related-party transactions with head office be priced so they are not adjusted by the Revenue Department?

· What does the Thai Revenue Department usually examine in a tax audit, and how should we respond to a notice?

· Under what circumstances is a transfer pricing document required for a Chinese-invested company in Thailand?

· Are there significant differences in tax burden for a Chinese-invested company in Thailand when repatriating funds in the form of dividends, service fees and technology royalties?

· When a Chinese enterprise investing in Thailand pays service fees or technology royalties to its China headquarters, what taxes need to be declared in Thailand?

Want advice tailored to your company? Book a transfer pricing consultation →

Z&X helps Chinese-invested companies in Thailand review related-party and cross-border payment arrangements. Some of our published content:

· Under what circumstances is a transfer pricing document required for a Chinese-invested company in Thailand?

· Are there significant differences in tax burden for a Chinese-invested company in Thailand when repatriating funds in the form of dividends, service fees and technology royalties?

· Top 10 Financial and Tax Pain Points for Chinese Enterprises Going Overseas to Thailand and Zhongxin Professional Solutions

· Our licenses and certificates: three licensed firms in China and Thailand

Want to check whether your related-party pricing would stand up to review? Book a transfer pricing consultation →

Articles from our Thailand Investment Guide related to this service:

· Thailand Signs the GloBE MCAA: Tax Information of Multinational Groups Will Be Exchanged

· Tax Information Exchange Violations: Fines of Up to THB 500,000 per Count

View all guide articles →