transfer pricing Division of Revenue Department have comment the possible tax risk involved with the provision of service to related company would arise from the assessment by Thai Revenue Offices is the transfer pricing issue. The Key issue is whether the compensation paid for such service is at arm's length or not.
Revenue Office determine arm's length price for purposes of computing revenues or expenses. The service fee is charged at a very large amount, we therefore would recommend ABC to prepare an explanation support to determine the service fee and whether such as fee is charged at the arm's length price in order to satisfy the corresponding Thai Law.
Swevice fee is higher than market value without justifiable grounds ,
the revenue office will have the power to assess such service fee to be at the market rate.