Holding companies
There is no specific legislation regarding holding companies.
Thin capitalization
Under the tax law, there are currently no thin capitalization or
prescribed debt to equity rules in Thailand.
Transfer pricing rules
The transfer pricing regulations issued by the Revenue Department
provide guidelines for related company transactions, which include a
definition of the term “market price”, details of the permitted
transfer pricing methods, a description of the transfer pricing
documentation requirements and a provision for advance pricing
agreements.
Legal framework
The transfer pricing guidelines do not have the status of legislation
but are internal directives that Thai Revenue officers must adhere to
when conducting tax audits, reviews or investigations. The guidelines
are also intended to inform taxpayers about Thai transfer
pricing practices.