On 15 October 2021, the Thai Revenue Department released guidance concerning the transfer pricing requirements with regard to country-by-country (CbC) reporting for accounting periods beginning on or after 1 January 2021. The guidance is referred to as Notification of the Director-General on Income Tax No. 408 (dated 30 September 2021). 

A summary of the guidance reflects the following:

  • The guidance on CbC reporting applies to multinational enterprise (MNE) groups that operate in more than one country through controlled entities, based on consolidated financial statements or permanent establishments, and that have total consolidated group revenue in the previous year of:

(a) not lower than THB 28 billion (approximately U.S. $839 million) in a 12-month accounting period, or

(b) not lower than a pro-rata of THB 28 billion in an accounting period of less than 12 months. If revenue is reported in other currencies, the amounts must be converted to THB based on the exchange rate (as announced by the Bank of Thailand).

  • The report is to be in writing and in English.
  • The report’s structure generally must follow the template for the CbC report as proposed by the OECD and must be filed in the OECD’s XML schema format.
  • The CbC report must be filed together with the annual corporate income tax return (form PND. 50) of the “reporting entity.”