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26 June 2015

Thailand considering first transfer pricing law

Content team

Thailand is considering the introduction of the country's first law relating to transfer pricing.

Draft legislation that is in line with Organisation for Economic Co-operation and Development guidance was approved by the nation's government last month.

If passed, the law would require businesses to report to the Thailand Revenue Department (TRD) with transfer pricing documentation up to 150 days after the accounting period has come to an end, Transfer Pricing Week reports. Any organisation that fails to comply could be fined up to 400,000 Thai baht (£7,518).

Benjamas Kullakattimas, tax partner at KPMG Thailand, commented: "We cannot now say what date the law will be effected. If the law is issued this year though, it is possible the TRD will want the taxpayer to start providing transfer pricing documentation from the 2015 tax year, due May 30th 2016."

At present, there is no specific legislation relating to transfer pricing in Thailand, with this new law further evidence of the greater scrutiny authorities are placing on this area of tax across the world.

In Ecuador, new regulations have been released that impact transfer pricing requirements. The threshold for producing full transfer pricing documentation has been increased, while supplementary content and supporting attachments are also required by the nation's tax authority.

This month has seen the G7 nations express a commitment to clamping down on tax aversion through transfer pricing. At a meeting of leaders in Germany, they revealed they will be scrutinising this practice in order to develop a "fair and modern international tax system" across the world.

Content team, Bureau van Dijk

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