TP Legal Framework And Practical Insights

1. Legal framework

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.

As a consequence, the Act Amending the Revenue Code on Transfer Pricing ("Transfer Pricing Act") was announced on 18 November 2018 and came into effect on 1 January 2019, requiring any company with annual revenue of over THB 200 million (approx. EUR 5 million) to submit a Transfer Pricing disclosure form together with its annual tax return.

Furthermore, Thailand signed the Multilateral Convention on Mutual Administrative Assistance in Tax Matters on 3 June 2020, becoming its 137th signatory state. Although the local laws regarding the automatic exchange of information requirements known as the Common Reporting Standard ("CRS") and CbCR are yet to be implemented, they will enable the automatic exchange and reporting of certain taxpayer information with other country revenue