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Thailand's Cabinet Approves Draft Transfer Pricing Legislation including Documentation Requirements

13 May 2015

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Proposed Changes

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Thailand

On 7 May 2015, Thailand's Cabinet approved draft transfer pricing legislation on adjustments and documentation requirements, which would be the first formal legislation on transfer pricing in the country. Current transfer pricing rules are limited to guidelines and instructions to the country's tax officials including that related party transactions must be at arm's length and that both traditional transaction methods and transactional profit methods may be used. Under the provisions of the draft legislation: Thai tax authorities are able to make adjustments to taxable income when transactions between related parties do not comply with the arm's length principle; Taxpayers with...