On 18 June 2019, the Cabinet approved in principle two draft ministerial regulations related to the Transfer Pricing Act that was released in November 2018. Key features are highlighted below.
- The first draft regulation grants tax officers the authority to adjust revenue and expenses incurred in connection with intercompany transactions if transfer prices are not in line with independent party dealings. The draft also stipulates criteria and conditions for transfer pricing audits.
- The second draft regulation grants taxpayers with annual revenue of less than Baht 200 million an exemption from the intercompany transaction reporting requirements under Section 71 ter of the Revenue Code, and explains the rationale behind granting the exemptions.
The above draft ministerial regulations would be effective from the accounting year starting on or after 1 January 2019.
Source: EY Tax Flash News for EY Thailand Website
Further details of these measures and associated regulations have yet to be announced.