By joining the Inclusive Framework on Base Erosion and Profit Shifting on 2 June 2017, Thailand committed itself to the implementation of the BEPS minimum standards.

The newly approved Transfer Pricing Act, which aims to regulate transfer pricing between Thai companies and affiliated companies, and will be added as Section 71 Bis to the Thai Revenue Code, will have a big impact on companies in Thailand.

On September 30, 2021, Thailand's Revenue Department released a notification prescribing country-by-country transfer pricing reporting requirements for multinational enterprise groups that do business in Thailand.

There is no formal order of preference for the use of the five accepted pricing methods.

As Thailand enters fiscal year 2026 (beginning 1 October 2025), attention turns to how the Thai Revenue Department (TRD) plans to strengthen its revenue collection, following last year's performance.

The global pharma sector presents specific issues and challenges from a transfer pricing perspective.

Latest Tax Issues And Practical Aspects For Successful Investment