We had a transfer pricing seminar for Japanese clients last week. We invited the Head of Transfer Pricing Audit and APA Working Team from the Thai Revenue Department, to be our speaker for Transfer Pricing Audit Trends in Thailand. We would like to provide you with the key information presented by the Head below. Please note that the information below is unofficial.
• Since October 2012, the transfer pricing audits will start performing the transfer pricing audits at the taxpayers’ offices/factories rather than waiting for taxpayers to provide information/documents. The transfer pricing audit and APA working team has started having a factory visit/tour for APA projects.
• The Head of transfer pricing audit team has provided transfer pricing trainings to local tax offices of Thai Revenue Department in each district/province. As a result, the tax officers in each local tax office is now starting to conduct transfer pricing audits by themselves.
• Moving toward AEC in 2015, the Thai Revenue Department is planning to set up an extra unit, the Bureau of International Taxation, to perform the transfer pricing audits and APAs and is planning to increase the number of transfer pricing auditors to examine international transactions.
• The Thai Revenue Department has drafted the specific transfer pricing laws and has designed the transfer pricing form to be required to be submitted with annual tax return. These specific transfer pricing laws have been waiting for cabinet’s approval.