This report is prepared in accordance with scope of the engagement letter dated 9 May 2014. The conclusions contained in this report are based on information provided by Mitsui Hygiene Materials (Thailand) Co., Ltd. (“MHM”)’s personnel. We disclaim any liability for advice based on incorrect or inaccurate information provided to us relating to the operations, financial data and pricing of MHM and its related parties.
In preparing this document, KPMG has relied on the Revenue Department Instruction No. Paw 113/2545 and followed the “four step process” as endorsed by the Revenue Department in an information brochure released in May 2002. These authorities are subject to change or modification by subsequent legislative, regulatory, administrative, or judicial decisions. Any such changes could have an effect on the results presented in this report. KPMG does not assume the obligation to reflect changes in the tax authorities noted above, business practices of the related parties or any other conditions impacting the related parties and comparable companies involved, subsequent to the time this report was commenced.
The objective of this report is to analyze whether, based on the transfer pricing rules of MHM, foreign related transactions conducted during the fiscal year ending March 2014 between MHM and its foreign related parties were carried out at arm’s length prices according to the arm’s length principle, and to document the results of this analysis.