Thailand’s Transfer Pricing Law – Lexology

Prior to June 2017, Thailand did not have transfer pricing law. The Revenue Department employed their power to adjust pricing to be at market price based on the provision of Section 65 bis (4) of the Revenue Code. That means the Revenue Department is empowered to adjust the selling price or service fee or interest rate in the case of transfer of assets, provision of service or lending of money without remuneration, fee or interest, or with remuneration, fee or interest that is lower than the market price, made without reasonable ground in accordance with the market price on the date of asset transfer, provision of service or lending of money. Besides, the Revenue Department has issued its Order No. Por 113/2545 (“Por 113/2545” or the “Guideline”) which sets out the arm’s length principles in 2002. Certain traditional transfer pricing methods were also suggested in the Guideline to…