Executive summaryThe Thai Revenue Department published Notification of Director-General of Revenue Department No. 408 (the Notice) on 30 September 2021, outlining the key requirements for the submission of a Thai transfer pricing Country-by-Country (CbC) report in Thailand, applicable to fiscal years staring on or after 1 January 2021. The CbC report is required to be submitted together with the annual corporate income tax return (PND 50) within 150 days after the fiscal year end.As the Notice is issued under Section 17 of the Revenue Code, the penalty for failure to submit a CbC report by the due date should be...