Thailand transfer pricing 2025 for SMEs and MNEs: disclosure form, local file, master file, and CbCR

Thailand transfer pricing 2025 for SMEs and MNEs: disclosure form, local file, master file, and CbCR

Introduction

Thailand has moved to a full Action 13 style framework. If your Thai company has related party dealings and revenue at or above 200 million THB, you must file an annual transfer pricing disclosure form and be ready to produce a local file and a master file when the Revenue Department asks. Multinationals that meet the Country by Country reporting threshold must also handle CbCR notifications and filings. This guide summarizes the legal bases, deadlines, and 2025 changes you should plan for.

Legal backbone you can cite

• Disclosure form threshold and deadline. The official TP disclosure form applies to Thai entities with total revenue of at least 200 million THB and is due within 150 days after year end. Thailand allows an 8 day extension for online filing.

• Local file and master file. Thailand requires a local file and a master file under Revenue Code Section 71 ter. Tax officers can request documentation and companies must submit it within a prescribed window.

• On request submission window. Practice materials explain the Revenue Department may require the file within 60 to 120 days from notice. Keep your package ready.

• CbCR framework. Thai CbCR rules took effect for fiscal years starting on or after 1 January 2021. Parent filers submit within 12 months of year end and local filing may be required within 60 days on request when conditions apply. A Thai group entity must submit the CbCR notification naming the reporting entity and fiscal year.

• Penalties. Guidance notes a penalty up to THB 200,000 for incomplete, late, or missing TP documentation, plus potential tax, surcharge, and interest for adjustments.

Thailand transfer pricing 2025 checklist

1) Confirm whether you hit the 200 million THB threshold

If your Thai entity’s annual revenue is 200 million THB or more, file the transfer pricing disclosure form with your year end calendar. The disclosure form sits alongside the corporate income tax cycle and is commonly filed online with the added 8 day window.

2) Build a defensible local file and master file

Prepare a Thai local file covering functional analysis, tested party, selection and application of methods, and benchmarking. Maintain a master file for group structure, intangibles, and financials. Thailand recognizes the standard five OECD methods in practice.

3) Calendar your CbCR notification and filing

• If your MNE group meets the Thai CbCR threshold, arrange the CbCR notification in Thailand naming the reporting entity and fiscal year, even if the ultimate or surrogate parent files abroad.

• Where the ultimate parent is in Thailand, file the CbCR within 12 months after the fiscal year end. Where local filing conditions apply, be ready to produce the report within 60 days on request.

4) Keep a response pack ready

Revenue officers can call for your local file and master file. Build a response pack you can deliver within 60 to 120 days that includes intercompany agreements, calculations, and evidence of services and benefits.

5) Watch the BEPS 2.0 link in 2025

Thailand enacted a Top up Tax Emergency Decree to implement Pillar Two for fiscal years beginning on or after 1 January 2025, with the first filing within 15 months of year end. While this is not transfer pricing documentation, Pillar Two data overlaps heavily with TP profiles and should be coordinated.

Filing calendar you can copy

• TP disclosure form due 150 days after year end, with 8 more days for e filing.

• CbCR notification due in line with Thai Revenue Department practice at the start of the CbCR cycle for the group’s Thai entities.

• CbCR filing by the parent in Thailand within 12 months after year end, or within 60 days on request under local filing conditions. Use a single dashboard to track the disclosure form deadline together with corporate income tax forms PND 50 and PND 51. KPMG’s 2025 Thailand tax calendar also flags the TP disclosure filing in the yearly cycle.

Frequently asked questions

Do small companies below 200 million THB need to do anything Yes. The arm’s length principle still applies. Keep intercompany agreements, pricing logic, and basic evidence. The disclosure form is not required if you remain below the threshold, but TP adjustments and penalties can still arise.

Which transfer pricing methods are accepted Thailand follows the standard five OECD methods in practice including CUP, resale price, cost plus, TNMM, and profit split. Choose the most appropriate method and be consistent across years.

What happens if I file late or cannot produce a file Expect administrative penalties up to THB 200,000 for documentation failures, plus assessments, surcharge and interest if prices are adjusted.

Who must file the CbCR notification in Thailand A Thai group entity must submit the CbCR notification on behalf of the MNE group, even if the reporting entity is outside Thailand.

What should be in the local file Functional analysis, tested party selection, method choice, benchmarking set, intercompany agreements, evidence of services received and benefits, and financial reconciliations consistent with the disclosure form.

How GENTLE LAW IBL executes and de risks Thailand transfer pricing 2025

• Calendar and controls. We map your fiscal year to the 150 day disclosure form window and the CbCR milestones, using the Thai 8 day e filing extension where available.

• Documentation quality. We produce Thai local files and group master files aligned to Section 71 ter expectations and the standard methods.

• CbCR posture. We prepare the Thai CbCR notification, confirm filing pathways, and reconcile entity lists and revenue thresholds against the Revenue Department’s guidance.

• Pillar Two link. We align TP narratives with 2025 top up tax computations to avoid inconsistencies.

Call to action

If you want a clean, audit ready program for Thailand transfer pricing 2025, GENTLE LAW IBL can prepare your disclosure form, draft Thai local files and master files, handle CbCR notifications, and coordinate with Pillar Two filings.

Book a consultation: https://www.gentlelawibl.com