On 27 September 2018, National Legislative Assembly released the revisions to the draft Transfer Pricing Act (the draft TP Act). The revenue threshold for subject to transfer pricing documentation is THB200 million (US$6 million) per year (increased from THB30 million per year in original draft).The new transfer pricing act will be effective for accounting years starting on or after 1 January 2019.
Taxpayers with related parties are required to make reports, including details of the related-party relationships and to disclose values of the related-party transactions for each fiscal year in accordance with the specified format, and submit them to the tax authority within 150 days from the ending of the accounting period. Failure to file the required report and/or additional documents/evidence or to submit incomplete/incorrect documents or evidence without a reasonable cause is subject to penalties.
