As NECTH’s profitability has continuously decreased, it may raise a red flag to a transfer pricing audit team of Thai Revenue Department. When a transfer pricing audit team conducts the audit, it normally requests the transfer pricing documentation (required by Departmental Instruction Paw 113/2545) for review first. Please find attached the Departmental Instruction Paw 113/2545 in Thai and English for your attention. The Thai Revenue Department suggests that the tax officers review the transfer pricing documentation (stated in Clause 4 of Paw 113). As a result, it is strongly recommended that the transfer pricing documentation should be prepared in advance.