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THAILAND 会計・税務 移転価格
【THAILAND】Request for submission of transfer pricing documentation (local files) from the Local Tax Office
2026.04.27
Overview
In Thailand, the November 2018 tax reform incorporated transfer pricing provisions into the Internal Revenue Code for the first time, applying to fiscal years beginning in January 2019 and beyond. Companies with sales exceeding 200 million baht that engage in related-company transactions are now required to report a detailed breakdown of their total annual related-company transactions (disclosure form) along with their corporate tax returns.
Recently, there has been an increase in cases where such companies receive letters from the tax office requesting the submission of local files. Upon receiving such a request, companies are required to prepare the local file and submit it within 180 days of the notification date.
Explanation:
The selection process for the target companies in this case is being led by the Central Revenue Authority, which manages the database. It is believed that after the selection of target companies, each tax office is notified and instructed to collect information from the companies. It has been reported that the selection was based on the following criteria:
- Companies that have submitted disclosure forms, and
- Companies belonging to a multinational enterprise group that submits Country by Country Reporting (CbCR), i.e., a group company whose ultimate parent company’s consolidated gross sales exceed 750 million euros.
While it is unclear what sales scale of Thai companies are being targeted, it is believed that companies with a considerable sales volume (500 million to 1 billion baht or more) are being targeted, including those experiencing fluctuations in profit margins or sharp declines in profits. It is reported that approximately 200 companies have currently received notifications.
The ultimate goal is to increase tax revenue, but it also appears to be intended to educate tax office staff on transfer pricing documentation and investigation methods. A sample translation of the letter is provided below; all documents are required by law.
Recommendation:
We recommend that your company create a local file containing information that can demonstrate the appropriateness of its transfer pricing. Please also refer to the following article:
JP: https://www.asahinetworks.com/library/thailand_library/922
Requested documents as mentioned in the letter:
If you have any concerns, please do not hesitate to contact us.
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