Tax Section - Doing Business

You will find here a series of summaries providing an overview of useful tax regulations, processes and tax issues for Doing Business in Thailand.

Transfer-pricing disclosure form

The transfer-pricing disclosure form is one which companies or legal partnerships that are related, as defined in Section 71 bis of the Revenue Code, must prepare and file together with an annual corporate income tax return within 150 days of the last day of the accounting period.

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Revenue and expenses in relation to related-party transactions

As mentioned in our technical update for November 2020, the Revenue Department issued Ministerial Regulation No. 369 to set out the rules, procedures, and conditions for Revenue Department officials to adjust corporate taxpayers’ revenue and expenses in relation to related-party transactions that are not at arm’s length. Subsequently, the Notification of the Director-General of the Revenue Department, No. 400 (“Notification No. 400”) was issued in order to provide further clarification on those rules, procedures, and conditions.

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VAT imposed on e-services

As approved by the Cabinet on 9 June 2020, the Act amending the Revenue Code (No. 53) to impose VAT on foreign-based operators that provide services to customers not registered for VAT in Thailand was published in the Royal Gazette on 10 February 2021.

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Requirement for e-filing of the TP disclosure form

Requirement for electronic filing of the transfer pricing disclosure form. Under the Notification, starting from an accounting period beginning on or after 1 January 2020, a company or legal partnership which is required to file the transfer pricing disclosure form must file the form electronically under the following procedures:

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Amendment of debt thresholds for writing off bad debts

The Cabinet recently approved the draft Ministerial Regulation to amend the debt thresholds required for compliance with the conditions of writing off bad debt under Ministerial Regulation No. 186 (M.R. 186).

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