Thailand Transfer Pricing Disclosure Form 2026: Who Must File and a Practical SME Roadmap

gentlelawlawfirm
2 days ago
8 min read

Introduction

If your Thailand company is part of a group, has a foreign parent, or trades with related entities, transfer pricing compliance is no longer optional admin. Thailand requires a yearly disclosure form for certain companies, and the Revenue Department can later request supporting documentation with strict time limits.

This guide explains the Thailand transfer pricing disclosure form 2026 in plain English: who must file, how related parties are defined, what triggers the filing obligation, what penalties apply, and a practical roadmap for foreign SMEs.

Legal disclaimer: This article is general information, not legal or tax advice for your specific facts. For a reliable position, your structure, transactions, and financials must be reviewed.

Key takeaways

The Thailand transfer pricing disclosure form 2026 is generally filed together with the annual corporate income tax return (PND.50) for qualifying companies.
Related parties are defined in the Revenue Code using an ownership threshold of at least 50 percent (direct or indirect) and certain control relationships.
The disclosure form obligation applies when total revenue shown in financial statements is at least THB 200 million for the relevant accounting period.
Penalties can be up to THB 200,000 if the disclosure form is not filed or is incorrect or incomplete without reasonable cause.
The Revenue Department can request transfer pricing documentation within 5 years after filing, with deadlines of 60 days (extendable to 120) and 180 days for the first request.

What is the Thailand transfer pricing disclosure form 2026

The Thailand transfer pricing disclosure form 2026 is an annual report about related parties and the total value of intercompany transactions. It is prepared in the format prescribed by the Revenue Department and filed with the corporate income tax filing timeline.

Important compliance point: the law can require the report even if you had no intercompany transactions in the year, as long as the related party relationship exists and you meet the filing criteria.

Thailand transfer pricing disclosure form 2026: Who must file

In general, you should assess the filing obligation using two questions:

Step 1: Do you have related parties under Thai law

Under the Revenue Code concept of related juristic persons, common triggers include:

Entity A holds at least 50 percent of the total capital in Entity B, directly or indirectly.
A shareholder holds at least 50 percent in Entity A and also at least 50 percent in Entity B, directly or indirectly.
Other capital, management, or control relationships where one entity cannot operate independently from the other, as prescribed by ministerial regulation.

Step 2: Do you meet the revenue threshold for reporting

The Revenue Department guidance for the annual disclosure form points to total revenue shown in the financial statements being at least THB 200 million for the accounting period tied to the PND.50 filing. The Revenue Code also provides that the rule does not apply for companies with revenue not exceeding the amount set in ministerial regulation, which must be at least THB 200 million.

Practical takeaway for foreign SMEs: if your Thailand entity has related parties and your financial statements show total revenue of THB 200 million or more, assume the Thailand transfer pricing disclosure form 2026 is in-scope, then confirm via your accountant or counsel.

Deadlines and where the disclosure fits with PND.50

Thailand’s corporate income tax return filing timeline is generally within 150 days from the end of the accounting period. The disclosure form is filed along with the annual corporate income tax return submission timeline.

Note: The Revenue Department may issue separate administrative extensions for certain e-filings in some years. Always confirm the current-year practice before your due date.

Penalties and audit exposure

If a company that must file does not file the disclosure form, or files incorrect or incomplete information without reasonable cause, the fine can be up to THB 200,000.

Separate from penalties, transfer pricing can drive tax adjustments. The Revenue Department has authority to adjust income and expenses to reflect arm’s length pricing principles in related party transactions.

What the Revenue Department can request later: documentation and strict time limits

Thailand’s transfer pricing regime has two layers in practice:

Annual reporting via the disclosure form
Supporting documentation that the Revenue Department can request later

The law allows the assessing officer, with Director-General approval, to request documents within 5 years after you file the disclosure report. You must comply:

Within 60 days from receipt of the notice
Extension may be granted, but not beyond 120 days from receipt
For the first notice, the deadline is 180 days

The Director-General Notification No. 407 sets content requirements for the documents used to analyze controlled transactions. It also states submission must be in Thai and indicates where to submit.

What documents are typically expected under Director-General Notification No. 407

Director-General Notification No. 407 is the key official content standard for transfer pricing documentation in Thailand. Its categories include, in substance:

Business overview materials such as local organization structure, value chain, key competitors, business strategy, and economic conditions
Related party group and ownership relationship details
Controlled transaction listing by type, counterparty, and jurisdiction, with amounts
Pricing policy and method explanations, including reasons for choosing the method and financial information supporting it
Key contracts and summaries of pricing-related terms
Functional analysis, meaning functions, assets, and risks, and comparability analysis concepts
Thai language requirement and filing location requirements

Also note: Notification No. 407 includes specific conditions where certain document submissions may not be required in some cases, such as when revenue is not over THB 500 million and other conditions are met, and other fact-specific conditions. Treat this as a technical area that must be tested against your exact facts.

Effective period note: Notification No. 407 applies for accounting periods beginning on or after 1 Jan 2021.

Common misconceptions

Misconception: “If there were no intercompany transactions, no filing is needed.”

Correction: The legal trigger references related party status and requires the report regardless of whether transactions occurred in the year, subject to the revenue threshold and scope rules.
Misconception: “Transfer pricing only matters for large multinationals.”

Correction: Thailand’s reporting threshold is revenue-based and group-relationship-based, which can capture mid-sized foreign-led SMEs.
Misconception: “The disclosure form is enough. No need to prepare documentation.”

Correction: The Revenue Department can request documentation later within 5 years, and deadlines are strict.

Worked scenarios (safe, conditional examples)

Scenario A: Foreign parent with Thai subsidiary, no intercompany invoices this year

Facts: A foreign parent owns 100 percent of a Thai company. Thai company revenue is THB 320 million.
Likely result: Related party status exists under ownership rules, revenue threshold is met, so the Thailand transfer pricing disclosure form 2026 should be assessed as required even if no transactions occurred.

Scenario B: Common shareholder controls two Thai companies, medium revenue

Facts: The same shareholder holds 60 percent in two Thai companies. One sells services to the other. Consolidated group presence exists. Company revenue is THB 180 million.
Likely result: Related party status may exist, but if total revenue shown in the financial statements is below the THB 200 million threshold, the annual disclosure form obligation may not apply. Still, arm’s length pricing discipline remains prudent because audits can focus on unusual margins and deductions.

Scenario C: Revenue above threshold and cross-border related party payments

Facts: Thai company pays management fees and royalty to foreign HQ and has revenue above THB 200 million.
Likely result: High audit attention. Prepare the disclosure carefully and build documentation that aligns with Notification No. 407 to reduce adjustment and penalty risk.

SME roadmap: how to be audit ready without overbuilding

This roadmap is designed for foreign SMEs that want compliance discipline with controlled cost.

Phase 1: Setup and scoping (Week 1 to 2)

Identify related parties using the 50 percent ownership and control tests.
Create a controlled transaction map: goods, services, royalties, interest, management fees, cost sharing.
Align who owns transfer pricing internally: finance lead plus one decision maker.

Phase 2: Disclosure readiness (Week 3 to 6)

Confirm whether total revenue shown in the financial statements is at least THB 200 million.
Build a clean intercompany transaction register by counterparty and jurisdiction.
Draft the narrative in plain terms: what the transaction is, why it exists, and how the price is determined.

Phase 3: Documentation readiness (Month 2 to 3)

Build the documentation pack aligned to Notification No. 407 categories: business overview, transaction details, method selection, financial support, and key contracts.
Prepare Thai language versions for submission readiness.
Set a “60-day response” drill: if a request arrives, you can compile and submit within the legal timeline.

Decision checklist and compliance checklist (copy-paste artifact)

Use this checklist to decide whether the Thailand transfer pricing disclosure form 2026 likely applies and to stay compliant.

Decision checklist:

Related parties exist under Revenue Code tests, including 50 percent ownership direct or indirect, or control as prescribed.
Total revenue shown in financial statements for the accounting period is THB 200 million or more.
You are filing PND.50 for that period and must file the disclosure form along with the annual filing timeline.

Compliance checklist:

Maintain an annual related party list and ownership chart.
Maintain a controlled transaction register with amounts, counterparties, and jurisdictions.
Keep intercompany contracts and pricing policy notes.
Prepare documentation aligned with Notification No. 407 and in Thai for submission if requested.
Keep files in a “ready within 60 days” format for the legal request window and deadline.

FAQ (AEO format, 8 questions)

What is the Thailand transfer pricing disclosure form 2026?

It is the annual report of related parties and intercompany transaction totals filed in the format prescribed by the Revenue Department. It links to the annual corporate tax filing timeline.
Who must file the Thailand transfer pricing disclosure form 2026?

Generally, companies with related parties and total revenue in financial statements of at least THB 200 million for the period should assess as in-scope. Related party definitions include 50 percent ownership and control relationships.
Do I have to file if I had no intercompany transactions this year?

Possibly yes. The law references filing based on related party status even if there were no transactions in the accounting period, subject to the revenue threshold and scope rules.
What is the penalty if I do not file or I file incorrectly?

A fine up to THB 200,000 can apply if the disclosure form is not filed or is incorrect or incomplete without reasonable cause.
Can the Revenue Department ask for supporting documents later?

Yes. A request can be issued within 5 years after filing, and the response deadline is typically 60 days, extendable to 120 days, with 180 days for the first request.
What documentation standard applies in Thailand?

Director-General Notification No. 407 specifies the categories of documents needed to analyze controlled transactions and requires submission in Thai.
Is transfer pricing only for cross-border transactions?

No. Related party rules can apply to domestic related parties too, but cross-border related party payments often attract higher audit focus.
What is the fastest safe way for an SME to become compliant?

Start with a related party map and transaction register, then draft the disclosure consistently with your financial statements, and build a documentation pack aligned to Notification No. 407 so you can respond quickly to any request.

Glossary (10 terms)

Arm’s length principle: Pricing related party transactions as if between independent parties.
Related parties: Juristic persons meeting ownership or control tests under Thai Revenue Code.
Controlled transaction: Transaction between related parties within scope for analysis under Notification No. 407.
PND.50: Annual corporate income tax return in Thailand.
Disclosure form: Annual transfer pricing report filed with the annual return timeline.
Documentation request notice: Formal notice that triggers the 60-day or 180-day submission deadlines.
Functional analysis: Analysis of functions, assets, and risks relevant to pricing.
Comparables: Independent transactions or companies used for pricing comparisons.
Revenue threshold: Total revenue per financial statements used to test disclosure obligation.
Director-General Notification No. 407: Thai Revenue Department notification specifying documentation content and Thai language submission.

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