Thailand Transfer Pricing Guide 2026: Sections 71 bis & 71 ter, 200M THB Threshold, Arm's Length Rules, Management Fee Defense & DTA Tax Audit Mitigation
Executive Summary: The Era of Aggressive Transfer Pricing Enforcement in Thailand
In late 2026, foreign multinational enterprises, regional conglomerates, and venture-backed cross-border groups operating in Thailand are navigating the most rigorous tax audit environment in the Kingdom's corporate history. The Thai Revenue Department (TRD) has systematically upgraded its audit capabilities, integrating advanced data analytics, cross-border electronic filing systems, and coordinated information exchanges under the OECD Base Erosion and Profit Shifting (BEPS) framework.
For decades, international parent companies treated intra-group recharge arrangements—such as centralized management service fees, shared IT infrastructure costs, regional executive oversight allocations, and software royalties—as standard commercial practices routinely deductible in Thailand. That operational complacency is now a catastrophic legal liability.
Under the Transfer Pricing Act B.E. 2561 (enacting Sections 71 bis and 71 ter of the Thai Revenue Code), coupled with Ministerial Regulation No. 370 and aggressive audit directives under Section 65 ter (13) and (14), the Thai Revenue Department possesses unfettered statutory authority to adjust corporate income, disallow intercompany expense deductions, impose punitive monthly surcharges of 1.5%, and levy statutory non-compliance fines up to 200,000 THB.
💡 Strategic Counsel Takeaway: A multinational company in Thailand cannot defend an intercompany payment merely by producing an offshore invoice or an annual head-office calculation spreadsheet. Without contemporaneous transfer pricing documentation, a comprehensive Local File, and robust proof satisfying the statutory 'Benefit Test', intercompany fees will be struck down during tax audits, triggering massive back-tax assessments and secondary withholding tax liabilities.
1. Statutory Foundations: Revenue Code Sections 71 bis and 71 ter
The statutory bedrock of Thailand's transfer pricing regime is codified within the Revenue Code Amendment Act (No. 47) B.E. 2561. This landmark legislation formally introduced the Arm's Length Principle into domestic Thai tax law and created a mandatory dual-track compliance system comprising statutory disclosure and substantiation documentation.
The Arm's Length Standard (Section 71 bis)
Section 71 bis establishes that where two or more juristic persons or partnerships possess a relationship, and commercial or financial conditions are established between them that differ from those that would be agreed between independent enterprises in an open, competitive market, the Revenue Department assessment officer is empowered to adjust the revenue and expenses of such entities to reflect the arm's length commercial reality.
This adjustment authority applies across all categories of controlled transactions, including the cross-border sale of goods, provision of technical or management services, licensing of intellectual property, and intra-group financing facilities.
Statutory Definition of 'Related Parties' (นิติบุคคลที่มีความสัมพันธ์กัน)
The statutory threshold establishing a 'related party' relationship under Section 71 bis is triggered upon the satisfaction of any of the following three legal criteria:
Direct or Indirect Shareholding Test: A juristic person holds shares or is a partner in another juristic person, directly or indirectly, representing not less than 50% of total equity capital or voting rights.
Common Ownership Test: A single shareholder or partner holds shares or is a partner in two or more juristic persons, directly or indirectly, representing not less than 50% of the total equity capital or voting rights of each respective entity.
Management & Operational Control Test: A relationship exists between juristic persons characterized by capital participation, management control, or operational dependency such that one entity possesses the legal or commercial authority to direct or control the business operations of the other entity.
2. Mandatory Reporting: The 200 Million THB Revenue Threshold (Section 71 ter)
Section 71 ter of the Revenue Code establishes a mandatory annual disclosure obligation for qualifying corporate taxpayers. Every company or juristic partnership operating in Thailand with total gross revenue of not less than 200,000,000 THB (Two Hundred Million Baht) within an accounting period must submit a formal Transfer Pricing Disclosure Form (TP Disclosure Form) to the Revenue Department.
Key Mechanics of the TP Disclosure Form
The TP Disclosure Form is submitted electronically via the Revenue Department's e-filing system concurrently with the annual corporate income tax return (Form P.N.D. 50), due within 150 days following the close of the company's fiscal year. The disclosure mandates exhaustive itemization of:
Full legal names, jurisdictions of incorporation, and tax identification numbers of all domestic and overseas related entities.
Detailed aggregate transaction values across controlled sales, service fees, royalty payments, interest on intercompany loans, and asset transfers.
Confirmation of whether the enterprise is legally required to prepare and maintain a contemporaneous Transfer Pricing Local File.
Disclosure of any corporate restructuring, business model changes, or intangible property transfers executed during the fiscal year.
The 'Under 200M THB' Fallacy: A Dangerous Misconception
One of the most dangerous legal misconceptions among foreign SME directors and startup founders is the belief that companies generating less than 200 Million THB in annual gross revenue are completely exempt from Thai transfer pricing laws. This assumption is legally false.
While an entity with annual revenue below 200 Million THB is exempt from submitting the annual TP Disclosure Form under Section 71 ter, it remains 100% subject to the substantive Arm's Length Principle under Section 71 bis. If a 50 Million THB subsidiary pays 15 Million THB in overseas 'management fees' or 'software licensing' to its Singaporean or US parent, the Revenue Department retains full statutory power to audit, challenge, and disallow those deductions under Section 71 bis and Section 65 ter.
💡 Strategic Counsel Takeaway: Exemption from the 200M THB Disclosure Form filing does NOT provide immunity from transfer pricing tax audits. Any cross-border intercompany transaction can be audited and adjusted under Section 71 bis regardless of company size.
3. The Transfer Pricing Local File: Structure, Timelines & Defense Architecture
Under Ministerial Regulation No. 370 and the Notifications of the Director-General of the Revenue Department (Transfer Pricing No. 1 and No. 2), taxpayers who meet the 200 Million THB threshold—or any taxpayer subject to an official transfer pricing audit—must prepare and maintain contemporaneous transfer pricing documentation known as the Local File.
Statutory Timelines for Submission
Unlike the TP Disclosure Form, which is submitted automatically each year with Form P.N.D. 50, the full Local File is submitted upon formal written notification from the Revenue Department assessment officer. Once a formal notice is served:
Statutory Window: The taxpayer must deliver the complete Local File within 60 days of receiving the written notice.
First-Time Extension: For taxpayers receiving their very first transfer pricing document request, a statutory extension of up to 120 days may be granted upon timely written application showing justifiable grounds.
Strict Evidentiary Preclusion: Failure to provide contemporaneous documentation within the statutory deadline severely prejudices the taxpayer's ability to challenge subsequent Revenue Department adjustments during administrative appeals or before the Central Tax Court.
Mandatory Structural Contents of a Defensible Local File
A statutory Local File compliant with Thai Revenue Department directives must incorporate seven core technical components:
1. Corporate Overview & Organization: Detailed corporate history, shareholding charts, organizational structure, and operational reporting lines between Thai management and overseas parent executives.
2. Business Model & Commercial Strategy: In-depth economic narrative of industry dynamics, market conditions, key competitors, and commercial strategy pursued by the Thai entity.
3. Controlled Transaction Schedule: Granular breakdown of all intercompany agreements, transaction flows, invoicing mechanisms, pricing policies, and payment terms.
4. Functional, Asset, and Risk (FAR) Analysis: Comprehensive legal and economic mapping of the functions performed, assets utilized (tangible and intangible), and commercial risks assumed by each related party in the transaction chain.
5. Transfer Pricing Methodology Selection: Detailed economic and legal rationale explaining why the chosen transfer pricing method is the most appropriate under Thai law.
6. Economic Comparability & Benchmarking Study: Quantitative benchmarking analysis utilizing accepted financial databases (such as Bureau van Dijk's Osiris, Orbis, or TP Catalyst) comparing the Thai taxpayer's financial margins against a screened sample of independent, comparable enterprises operating in Thailand or Southeast Asia.
7. Intercompany Legal Agreements: Complete, fully executed copies of all bilateral intercompany service agreements (ICSA), intellectual property licensing contracts, distribution agreements, and financial loan covenants.
4. The 5 Approved Transfer Pricing Methodologies in Thailand
Ministerial Regulation No. 370 establishes five statutory transfer pricing methodologies, derived from the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. Corporate taxpayers must select the 'Most Appropriate Method' based on the specific economic characteristics of the transaction, the availability of reliable data, and the degree of comparability.
1. Comparable Uncontrolled Price (CUP) Method
Compares the price charged for property or services transferred in a controlled transaction to the price charged for property or services transferred in a comparable uncontrolled transaction under comparable circumstances. The CUP method is the most direct and reliable measure of arm's length pricing when highly standardized commodities or open-market financial products are involved, but is rarely feasible for complex management services or proprietary technology.
2. Resale Price Method (RPM)
Evaluates whether the gross profit margin earned by a related distributor in reselling products purchased from an affiliate to independent customers is at arm's length. Primarily applied to marketing and distribution subsidiaries in Thailand that purchase finished goods from overseas related manufacturers without adding substantial physical value.
3. Cost Plus Method (CPM)
Evaluates whether the gross mark-up added to direct and indirect costs incurred by a related supplier or service provider conforms to arm's length margins earned by independent suppliers. Widely utilized for contract manufacturing entities, toll manufacturing operations, and back-office technical service centers located in Thailand.
4. Transactional Net Margin Method (TNMM)
Examines the net profit margin relative to an appropriate base (e.g., costs, sales, assets) that a taxpayer realizes from a controlled transaction. TNMM is by far the most commonly adopted methodology for multinational corporate subsidiaries in Thailand, particularly service providers and limited-risk distributors. Key profit level indicators (PLIs) include:
Full Cost Mark-Up (FCMU): Net operating profit divided by total operating costs, standard for shared service centers, routine administrative support, and regional engineering hubs.
Operating Margin (OM): Operating profit divided by net sales, typical for commercial distribution entities.
Return on Assets (ROA): Operating profit divided by total operating assets, common for capital-intensive manufacturing facilities.
5. Profit Split Method (PSM)
Identifies the combined total profit resulting from controlled transactions and allocates that profit between related parties based on their relative economic contributions, functions, and unique intangibles. Applied in highly integrated international business operations where both the Thai entity and the overseas affiliate contribute unique, highly valuable intellectual property or assume shared entrepreneurial risks.
5. The Intercompany Management Fee Trap: Surviving Section 65 ter Audits
Of all transfer pricing inquiries conducted by the Thai Revenue Department, none generates greater financial devastation than audits targeting Intercompany Management Service Agreements (ICSA), regional head-office shared services, and centralized technology charges. Tax inspectors approach intra-group service recharges with institutional skepticism, viewing them as artificial mechanisms designed to strip taxable profits out of Thailand prior to corporate income tax assessment.
The Lethal Weapon: Section 65 ter (13) and Section 65 ter (14)
When challenging intercompany management fees, Revenue Department assessment officers rarely limit themselves to transfer pricing adjustments under Section 71 bis. Instead, they invoke the absolute disallowance provisions of Section 65 ter:
Section 65 ter (13): Explicitly prohibits the tax deduction of 'expenses not exclusively incurred for the purpose of business in Thailand' (รายจ่ายที่มิได้จ่ายไปเพื่อกิจการในประเทศไทยโดยเฉพาะ).
Section 65 ter (14): Prohibits the deduction of 'expenses not exclusively incurred for the purpose of acquiring profits or for the purpose of business' (รายจ่ายที่ไม่สมควรหรือมิได้จ่ายเพื่อการหากำไร).
If the Revenue Department invokes Section 65 ter (13), the entire management fee deduction is disallowed 100%. The company is assessed 20% Corporate Income Tax on the disallowed amount, plus a statutory surcharge of 1.5% per month, retroactively calculated.
The Statutory Three-Pillar Defense Framework
To successfully defend intercompany management fees against Section 65 ter and Section 71 bis challenges, a Thai corporate subsidiary must rigorously satisfy three cumulative legal tests:
1. The Benefit Test (การได้รับประโยชน์ทางเศรษฐกิจจริง): The company must prove that the services rendered by the overseas affiliate provided real, quantifiable economic or commercial value to the Thai entity's operations. The services must enhance the commercial position of the Thai business or result in cost savings.
2. The Non-Duplication Test (การไม่ซ้ำซ้อนกับงานในประเทศ): The taxpayer must establish that the services provided from abroad were not duplicative of functions already performed by local Thai employees, local contractors, or in-house executives.
3. The Shareholder Stewardship Exclusion (ไม่ใช่กิจกรรมของผู้ถือหุ้น): Under OECD standards adopted by the TRD, expenses relating to 'shareholder activities' (such as parent board meetings, global shareholder relations, parent stock exchange filings, or group consolidation audits) are incurred solely for the benefit of the parent company and cannot legally be charged to the Thai subsidiary.
The Contemporaneous Evidence Dossier
To satisfy the Benefit Test, a company cannot rely on broad contractual statements such as 'Parent will provide general strategic management.' The taxpayer must maintain a contemporaneous evidentiary dossier comprising:
Detailed, signed bilateral Intercompany Service Agreements (ICSA) clearly defining the scope of services, billing formulas, and cost allocation keys.
Timesheets, project logs, and electronic calendars showing exact hours dedicated by foreign specialists to Thai operations.
Concrete work deliverables: Regional market reports, software source code updates, training presentation decks, internal audit reports, and email threads addressing specific Thai legal or commercial problems.
Transparent cost allocation keys (e.g., proportion of headcount, transaction volumes, or verified system usage hours) demonstrating that head-office cost pools were not arbitrarily allocated.
6. Cross-Border Royalties & Intellectual Property Licensing (DEMPE Rules)
Intra-group licensing of trademarks, proprietary software, industrial patents, and specialized technical know-how represents another prime target for Revenue Department scrutiny. Where a Thai subsidiary pays recurring royalties or software license fees to an overseas affiliate, tax authorities evaluate both the arm's length quantum and the substantive economic reality of the intellectual property.
The DEMPE Economic Analysis
In line with OECD Action 8-10 standards, the Thai Revenue Department examines which entity within the corporate group actually executes the DEMPE functions:
Development: Who designed and created the underlying software or intangible property?
Enhancement: Who actively finances and executes system upgrades and technical improvements?
Maintenance: Who maintains legal registrations, server infrastructure, and bug fixes?
Protection: Who enforces patents, trademarks, and copyright against third-party infringement?
Exploitation: Who utilizes the intangible asset in commercial market operations?
If a foreign parent company is merely a passive legal shell that outsourced all software development to independent third parties, paying high-percentage royalties from Thailand to that shell entity will be attacked as artificial profit shifting.
Withholding Tax & Reverse Charge VAT Intersection
Cross-border royalty payments trigger dual indirect tax obligations in Thailand:
Withholding Tax (Form P.N.D. 54): Under Section 70 of the Revenue Code, royalties paid to a foreign company not carrying on business in Thailand are subject to a statutory 15% Withholding Tax. This rate may be reduced to 5%, 8%, or 10% under applicable bilateral Double Taxation Agreements (DTAs), subject to submitting official Certificate of Tax Residency from the recipient jurisdiction.
Reverse Charge VAT (Form P.P. 36): Under Section 83/6 (4) of the Revenue Code, the Thai paying company must self-assess and remit 7% VAT on service fees and royalties paid to foreign entities within 7 days of the following month. While this VAT is generally creditable as input VAT in subsequent filings, failure to remit on time triggers separate tax fines and interest.
7. Intercompany Financing, Intra-Group Loans & Interest Rate Benchmarking
Financial transactions between related corporate entities—including intercompany loans, cash pooling structures, and corporate guarantees—must be executed on strict arm's length terms under Section 71 bis.
Interest Rate Determination & Thai Market Benchmarks
Historically, many foreign companies extended interest-free loans or nominal 0.5% loans to their Thai subsidiaries. Under Section 65 bis (4) and Section 71 bis, the Revenue Department treats loans without interest or with interest below market rates as a deemed revenue event for the lender, or challenges excessive interest deductions for the borrower.
Interest rates on intra-group loans must be benchmarked against prevailing commercial bank lending rates in Thailand (such as the Minimum Loan Rate - MLR, or Minimum Overdraft Rate - MOR published by the Bank of Thailand) or international risk-adjusted benchmarks (such as SOFR or SIBOR plus a justifiable credit spread based on the borrower's credit standing).
Thin Capitalization & Section 65 ter Debt Scrutiny
While Thailand does not possess a codified statutory thin capitalization statute with rigid debt-to-equity ratios for general commercial enterprises (unlike specialized regimes under BOI regulations or Foreign Business Licenses, which enforce a 3:1 or 7:1 ratio), the Revenue Department aggressively scrutinizes debt-heavy subsidiaries under Section 65 ter. If a subsidiary is capitalized with nominal equity (e.g., 1 Million THB) and funded with 200 Million THB in high-interest intercompany debt, tax auditors may reclassify interest payments as non-deductible constructive dividends.
8. Assessment Liabilities: Penalties, Surcharges & Constructive Dividends
The financial consequences of an adverse transfer pricing audit in Thailand are severe, compounding across multiple statutory layers:
Statutory Penalty Matrix
Section 35 ter Non-Compliance Fine: Failure to file the annual TP Disclosure Form, late filing, or submitting incomplete or inaccurate documentation carries a direct criminal fine of up to 200,000 THB.
Section 27 Monthly Surcharge: A statutory monthly surcharge (interest) of 1.5% per month (18% per annum) calculated on the unpaid tax from the original due date until payment. The surcharge can accumulate up to 100% of the underlying tax assessment.
Section 22 & 26 Tax Penalties: Where the Revenue Department issues a formal tax assessment notice (หนังสือแจ้งการประเมิน), a statutory penalty of 100% (for underpaid tax on filed returns) or 200% (for failure to file a return) is imposed. While penalties can be mitigated through formal administrative petitions, monthly surcharges cannot be waived under Thai law.
Secondary Withholding Tax Liabilities (Section 70): If the Revenue Department disallows 20 Million THB of overseas management fees paid to a foreign parent, it may recharacterize that payment as a deemed distribution of profits (constructive dividend), triggering an additional 10% Withholding Tax assessment under Section 70, with its own independent penalties and surcharges.
Statute of Limitations: Under Section 19 and Section 3 paragraph 2 of the Revenue Code, the standard assessment window is 2 to 5 years, extending up to 10 years in circumstances involving alleged tax fraud, evasion, or deliberate non-disclosure.
9. International Relief: Double Taxation Agreements (DTAs), MAP & APAs
Multinational corporate groups facing transfer pricing adjustments in Thailand can access formal international treaty mechanisms under Thailand's network of 61 bilateral Double Taxation Agreements (DTAs).
Article 9 (Associated Enterprises) & Corresponding Adjustments
When the Thai Revenue Department adjusts the taxable income of a Thai subsidiary upwards (a 'primary adjustment'), the overseas affiliate in Singapore, Japan, or the United States faces economic double taxation—the same profit has been taxed twice. Under Article 9(2) of standard DTAs, the overseas tax authority is requested to make a 'corresponding adjustment', reducing the foreign affiliate's taxable profit.
The Mutual Agreement Procedure (MAP)
Where double taxation cannot be resolved bilaterally by the taxpayer, the enterprise may formally initiate a Mutual Agreement Procedure (MAP) under the relevant DTA. Under MAP, the Competent Authority of Thailand (the Director-General of the Revenue Department) engages in direct government-to-government negotiations with the foreign competent tax authority (e.g., IRAS Singapore, IRS USA, HMRC UK) to reach an equitable allocation of taxable profits.
Advance Pricing Agreements (APAs)
For multinational enterprises with substantial recurring cross-border transaction volumes, negotiating an Advance Pricing Agreement (APA) represents the gold standard in tax risk elimination. An APA is a formal, legally binding bilateral or unilateral agreement between the taxpayer and the Revenue Department establishing the transfer pricing methodology, comparable benchmarks, and critical assumptions for a prospective period of 3 to 5 years, completely shielding the enterprise from transfer pricing audits during the agreement term.
10. The Gentle Law 10-Point Pre-Audit Transfer Pricing Checklist
Foreign managing directors, regional corporate counsel, and CFOs should immediately conduct a comprehensive internal audit across the following ten high-risk operational checkpoints:
[ ] 1. 200M THB Revenue Audit: Calculate total gross accounting revenue to verify whether mandatory Section 71 ter Disclosure Form filing is required for the current fiscal year.
[ ] 2. Related Party Register: Maintain an up-to-date, verified register of all domestic and overseas entities meeting the 50% direct/indirect equity or common control test under Section 71 bis.
[ ] 3. Bilateral Contract Completeness: Ensure every intercompany transaction (services, IP, goods, loans) is governed by a fully executed, dated written agreement reflecting arm's length commercial terms.
[ ] 4. Benefit Test Documentation: Compile a contemporaneous evidentiary dossier (timesheets, project deliverables, specialist work logs) proving actual economic benefit received in Thailand for all management fees.
[ ] 5. Non-Duplication Verification: Document and certify that services provided by offshore affiliates do not duplicate existing Thai in-house operational capabilities.
[ ] 6. Shareholder Stewardship Screening: Audit head-office cost allocation pools to strip out any shareholder activities, investor relations, or parent board expenses prior to charging the Thai entity.
[ ] 7. Benchmarking Study Validity: Verify that transfer pricing benchmarking studies are updated every 3 years, with financial data refreshed annually using accepted Thai/ASEAN databases.
[ ] 8. Intangible Royalty Justification: Ensure royalty rates conform to DEMPE economic realities and are supported by official Certificates of Tax Residency for DTA withholding tax relief.
[ ] 9. Intra-Group Loan Terms: Review all loan agreements to ensure interest rates align with Bank of Thailand commercial benchmarks (MLR/MOR) or verified SOFR/SIBOR spreads.
[ ] 10. 60-Day Readiness Protocol: Establish internal accounting readiness to produce the complete statutory Local File within 60 days of receiving a written Revenue Department notice.
11. Frequently Asked Questions: Thai Transfer Pricing Legal Briefing
Q1: What is the statutory threshold for filing a Transfer Pricing Disclosure Form in Thailand?
Under Section 71 ter of the Revenue Code, any company or juristic partnership operating in Thailand with total gross revenue of not less than 200 Million THB within an accounting period must submit the Transfer Pricing Disclosure Form alongside Form P.N.D. 50 within 150 days of fiscal year-end.
Q2: If our Thai company has revenue under 200 Million THB, are we completely exempt from transfer pricing audits?
No. While companies under 200 Million THB are exempt from the annual Disclosure Form, they remain fully subject to the Arm's Length Principle under Section 71 bis. The Revenue Department has statutory power to audit and adjust any cross-border intercompany transaction regardless of revenue.
Q3: What are the statutory penalties for failing to file the Transfer Pricing Disclosure Form?
Under Section 35 ter of the Revenue Code, failure to submit the TP Disclosure Form within the statutory deadline, or submitting incomplete or inaccurate documentation, carries a criminal fine of up to 200,000 THB.
Q4: How long does a company have to submit the full Transfer Pricing Local File after receiving a notice?
A taxpayer has 60 days from the date of receiving formal written notification from the assessment officer. A first-time recipient may request a statutory extension of up to 120 days upon showing justifiable grounds.
Q5: Why does the Revenue Department frequently disallow intercompany management fees under Section 65 ter (13)?
Section 65 ter (13) prohibits deducting expenses not exclusively incurred for the purpose of business in Thailand. Management fees are disallowed when the taxpayer fails to prove actual economic benefit received in Thailand through contemporaneous timesheets, project deliverables, and non-duplication evidence.
Q6: What transfer pricing methodologies are legally recognized under Thai law?
Ministerial Regulation No. 370 recognizes five methodologies: 1. Comparable Uncontrolled Price (CUP), 2. Resale Price Method (RPM), 3. Cost Plus Method (CPM), 4. Transactional Net Margin Method (TNMM), and 5. Profit Split Method (PSM).
Q7: What is the monthly surcharge (interest) rate on unpaid taxes resulting from transfer pricing adjustments?
Under Section 27 of the Revenue Code, a statutory surcharge of 1.5% per month (18% per annum) is imposed on unpaid tax liabilities from the original filing deadline, accumulating up to 100% of the underlying tax amount.
Q8: Can intercompany loans be extended interest-free between related group companies in Thailand?
No. Under Section 65 bis (4) and Section 71 bis, intercompany loans must carry an arm's length market interest rate. Extending interest-free loans triggers deemed interest income assessments on the lender under Bank of Thailand commercial lending benchmarks.
Q9: What is the statute of limitations for the Thai Revenue Department to conduct a transfer pricing audit?
The standard assessment window is 2 to 5 years from the filing date, extending up to 10 years in cases involving suspected tax fraud, deliberate tax evasion, or false corporate disclosures.
Q10: How can a multinational enterprise secure prospective certainty against Thai transfer pricing audits?
A multinational enterprise can negotiate an Advance Pricing Agreement (APA) with the Thai Revenue Department (bilaterally or unilaterally), establishing binding transfer pricing terms and benchmarking assumptions for a prospective period of 3 to 5 years.
12. Statutory Legal Notice & Confidential Corporate Counsel
Statutory Informational Notice: This publication provides general corporate legal and tax commentary pursuant to the Thai Lawyers Act B.E. 2528 and is intended exclusively for educational and strategic risk-mitigation purposes. It does not constitute formal legal or tax counsel, nor does it establish an attorney-client relationship. Cross-border transfer pricing structures, intercompany contracts, and tax audit defenses must be customized to the specific factual, functional, and contractual architecture of each corporate enterprise.
GENTLE LAW International Business Law advises multinational corporations, foreign corporate directors, and regional executive boards on transfer pricing compliance, Intercompany Service Agreement (ICSA) drafting, Local File substantiation, and Revenue Department audit defense in Bangkok and across ASEAN.
For confidential, privileged corporate tax counsel or an independent transfer pricing health check, contact our senior corporate practice group:
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