- Updated
- October 2025
- Sections
- 14
- Questions
- 37
Key Facts
Core Framework
Section 71 bis, Paragraph 1 of the Revenue Code [LINK] [LINK] Ministerial Regulation No. 369 (B.E. 2563) dated 16 November 2020 [LINK] Notification of Director-General of the Revenue Department on Income Tax No. 400 (B.E.2564) dated 14 January 2021 [LINK]
Ministerial Regulation No. 369 (B.E. 2563) dated 16 November 2020 [LINK] Notification of Director-General of the Revenue Department on Income Tax No. 400 (B.E.2564) dated 14 January 2021 [LINK]
Thailand does not formally accord legal binding status to the OECD Transfer Pricing Guidelines, but it recognises the OECD TPG as an important reference framework for transfer pricing.
Notification of Director-General of the Revenue Department on Income Tax No. 400 (B.E.2564) dated 14 January 2021 [LINK]
Thailand employs the Interquartile Range (IQR) as a statistical benchmark measure under the arm’s length principle, permitting adjustments to the most appropriate point based on case-specific analysis.
Documentation
Section 71 Ter of the Revenue Code [LINK] [LINK] Notification of Director-General of the Revenue Department on Income Tax No. 407 (B.E.2564) dated 30 September 2021 [LINK] Notification of Director-General of the Revenue Department on Income Tax No. 408 (B.E.2564) dated 30 September 2021 [LINK] Notification of Director-General of the Revenue Department Re: Information concerning Related Companies or Juristic Partnerships and the Total Value of Transactions between Them in Each Accounting Period dated 14 January 2021 [LINK] and date 18 January 2022 [LINK]
Section 71 Ter of the Revenue Code [LINK] [LINK] Notification of Director-General of the Revenue Department on Income Tax No. 407 (B.E.2564) dated 30 September 2021 [LINK] Notification of Director-General of the Revenue Department on Income Tax No. 408 (B.E.2564) dated 30 September 2021 [LINK] Notification of Director-General of the Revenue Department Re: Information concerning Related Companies or Juristic Partnerships and the Total Value of Transactions between Them in Each Accounting Period dated 14 January 2021 [LINK] and date 18 January 2022 [LINK]
Section 71 Ter of the Revenue Code [LINK] [LINK] Notification of Director-General of the Revenue Department on Income Tax No. 407 (B.E.2564) dated 30 September 2021 [LINK] Notification of Director-General of the Revenue Department on Income Tax No. 408 (B.E.2564) dated 30 September 2021 [LINK] Notification of Director-General of the Revenue Department Re: Information concerning Related Companies or Juristic Partnerships and the Total Value of Transactions between Them in Each Accounting Period dated 14 January 2021 [LINK] and date 18 January 2022 [LINK]
Section 35 Ter of the Revenue Code [LINK] [LINK]
Failure to submit transfer pricing reports, documents, or evidence, or submitting transfer pricing reports, documents, or evidence that contain incomplete or incorrect information without a reasonable cause, will be subject to a penalty of up to 200,000 Baht.
TP Methods
- CUP
- Resale Price
- Cost Plus
- TNMM
- Profit Split
- Other
Selection: Most appropriate method
Dispute Resolution
Mutual Agreement Procedure Provision of Thailand’s tax treaty network [LINK] Thailand’s MLI Position concerning Mutual Agreement Procedure Provision [LINK] No. 13 of the Notification of Director-General of the Revenue Department on Income Tax No. 400 (B.E.2564) dated 14 January 2021 [LINK] Guideline on APA Process [LINK] Mutual Agreement Procedure (MAP) Guideline [LINK] Thailand Dispute Resolution Country Profile
Advance Pricing Agreements (APA) [Bilateral APAs] and Mutual Agreement Procedures are available.
Mutual Agreement Procedure Provision of Thailand’s tax treaty network [LINK] Thailand’s MLI Position concerning Mutual Agreement Procedure Provision [LINK] No. 13 of the Notification of Director-General of the Revenue Department on Income Tax No. 400 (B.E.2564) dated 14 January 2021 [LINK] Guideline on APA Process [LINK] Mutual Agreement Procedure (MAP) Guideline [LINK] Thailand Dispute Resolution Country Profile
Advance Pricing Agreements (APA) [Bilateral APAs] and Mutual Agreement Procedures are available.
Simplifications
Amount B is still under consideration.
Special Topics
No.10 of the Notification of Director-General of the Revenue Department on Income Tax No. 400 (B.E.2564) dated 14 January 2021 [LINK]
Yes, Thailand follows the guidance in Chapter VI of the TPG.
Thailand’s domestic legislation does not contain specific guidance on the hard-to value intangibles (HTVI). As a source of interpretation, the TPG are used.
No.9 of the Notification of Director-General of the Revenue Department on Income Tax No. 400 (B.E.2564) dated 14 January 2021 [LINK]
Yes, Thailand follows the guidance in Chapter VII of the TPG.
Thailand’s domestic legislation does not contain specific guidance on financial transactions. As a source of interpretation, the TPG are used.
Full OECD Questionnaire
Legal ReferenceSection 71 bis, Paragraph 1 of the Revenue Code [LINK] [LINK] Ministerial Regulation No. 369 (B.E. 2563) dated 16 November 2020 [LINK] Notification of Director-General of the Revenue Department on Income Tax No. 400 (B.E.2564) dated 14 January 2021 [LINK]
Legal ReferenceMinisterial Regulation No. 369 (B.E. 2563) dated 16 November 2020 [LINK] Notification of Director-General of the Revenue Department on Income Tax No. 400 (B.E.2564) dated 14 January 2021 [LINK]
Thailand does not formally accord legal binding status to the OECD Transfer Pricing Guidelines, but it recognises the OECD TPG as an important reference framework for transfer pricing.
Legal ReferenceSection 71 bis, Paragraph 2 of the Revenue Code [LINK] [LINK]
A reference to a definition of related companies or juristic partnerships applicable for transfer pricing purpose is provided under Section 71 bis, Paragraph 2 of the Revenue Code. It should be noted that Section 71 bis, Paragraph 2 (3) of the Revenue Code has yet to enforced.
Legal ReferenceNo. 5 of the Notification of Director-General of the Revenue Department on Income Tax No. 400 (B.E.2564) dated 14 January 2021 [LINK]
Thailand’s transfer pricing framework accommodates alternative transfer pricing method under exceptional circumstances, provided the taxpayer justifies their necessity and appropriateness in line with arm’s length principle. In such instances, the taxpayer must formally notify the Director-General of the Revenue Department in writing within the relevant accounting period, accompanied by a preliminary justification for the selected methodology.
- CUP (provided)
- Resale Price (provided)
- Cost Plus (provided)
- TNMM (provided)
- Profit Split (provided)
- Other (provided)
Legal ReferenceNo. 5 and No.6 of the Notification of Director General of the Revenue Department on Income Tax No. 400 (B.E.2564) dated 14 January 2021 [LINK]
Most appropriate method
- Hierarchy of methods (not selected)
- Most appropriate method (selected)
- Other (if so, please explain) (not selected)
For controlled transactions involving commodities, the guidance contained in paragraphs 2.18-2.22 of the TPG is followed.
Legal ReferenceNotification of Director-General of the Revenue Department on Income Tax No. 400 (B.E.2564) dated 14 January 2021 [LINK]
Thailand employs the Interquartile Range (IQR) as a statistical benchmark measure under the arm’s length principle, permitting adjustments to the most appropriate point based on case-specific analysis.
Legal ReferenceNo.3 (2) and No. 4 of the Notification of Director-General of the Revenue Department on Income Tax No. 400 (B.E.2564) dated 14 January 2021 [LINK]
Legal ReferenceNo.10 of the Notification of Director-General of the Revenue Department on Income Tax No. 400 (B.E.2564) dated 14 January 2021 [LINK]
Yes, Thailand follows the guidance in Chapter VI of the TPG.
Thailand’s domestic legislation does not contain specific guidance on the hard-to value intangibles (HTVI). As a source of interpretation, the TPG are used.
Legal ReferenceNo.9 of the Notification of Director-General of the Revenue Department on Income Tax No. 400 (B.E.2564) dated 14 January 2021 [LINK]
Yes, Thailand follows the guidance in Chapter VII of the TPG.
Thailand’s domestic legislation does not contain specific guidance on financial transactions. As a source of interpretation, the TPG are used.
Thailand’s transfer pricing framework does not explicitly restrict taxpayer from establishing Cost Contribution Arrangements (CCAs). However, such arrangements must adhere to the arm’s length principle to ensure compliance with transfer pricing regulations.
Legal ReferenceSection 71 Ter of the Revenue Code [LINK] [LINK] Notification of Director-General of the Revenue Department on Income Tax No. 407 (B.E.2564) dated 30 September 2021 [LINK] Notification of Director-General of the Revenue Department on Income Tax No. 408 (B.E.2564) dated 30 September 2021 [LINK] Notification of Director-General of the Revenue Department Re: Information concerning Related Companies or Juristic Partnerships and the Total Value of Transactions between Them in Each Accounting Period dated 14 January 2021 [LINK] and date 18 January 2022 [LINK]
- Master file consistent with Annex I to Chapter V of the TPG (not selected)
- Local file consistent with Annex II to Chapter V of the TPG (selected)
- Country-by-country report consistent with Annex III to Chapter V of the TPG (selected)
- Specific transfer pricing returns (separate or annexed to the tax return) (selected)
- Other (specify) (not selected)
Legal ReferenceSection 71 Ter of the Revenue Code [LINK] [LINK] Ministerial Regulation No. 370 (B.E. 2563) dated 6 November 2020 [LINK] Notification of Director-General of the Revenue Department on Income Tax No. 407 (B.E.2564) dated 30 September 2021 [LINK] Notification of Director-General of the Revenue Department on Income Tax No. 408 (B.E.2564) dated 30 September 2021 [LINK] Thailand’s CbCR Local Guidance [LINK]
1. Disclosure Form: submitted within 150 days from the end of the accounting period. 2. Local File: submitted in Thai within 180 days from notification for the first submission, and 60 days for subsequent. 3. CbC Report: MNE groups with consolidated global revenue below THB 28 billion are exempt.
Legal ReferenceSection 35 Ter of the Revenue Code [LINK] [LINK]
Failure to submit transfer pricing reports, documents, or evidence, or submitting transfer pricing reports, documents, or evidence that contain incomplete or incorrect information without a reasonable cause, will be subject to a penalty of up to 200,000 Baht.
Legal ReferenceSection 71 Ter, Paragraphs 3 of the Revenue Code [LINK] [LINK] Ministerial Regulations No. 370 (B.E. 2563) dated 6 November 2020 [LINK] No.3 of the Notification of Director-General of the Revenue Department on Income Tax No. 407 (B.E.2564) dated 30 September 2021 [LINK] No. 5 of the Notification of Director-General of the Revenue Department on Income Tax No. 408 (B.E.2564) dated 30 September 2021 [LINK]
1. Disclosure Form: exempted if total revenue does not exceed THB 200 million. 2. Local File: General exemption (revenue <= THB 200 million); Specific exemption for benchmarking study (revenue <= THB 500 million under certain conditions or if an APA is in place). 3. CbCR: Thailand follows internationally aligned standards.
Legal ReferenceMutual Agreement Procedure Provision of Thailand’s tax treaty network [LINK] Thailand’s MLI Position concerning Mutual Agreement Procedure Provision [LINK] No. 13 of the Notification of Director-General of the Revenue Department on Income Tax No. 400 (B.E.2564) dated 14 January 2021 [LINK] Guideline on APA Process [LINK] Mutual Agreement Procedure (MAP) Guideline [LINK] Thailand Dispute Resolution Country Profile
Advance Pricing Agreements (APA) [Bilateral APAs] and Mutual Agreement Procedures are available.
- Rulings (not selected)
- Enhanced engagement or cooperative compliance programmes (not selected)
- Advance Pricing Agreements (APA) (selected)
- Mutual Agreement Procedures (selected)
- Other (please specify) (not selected)
Amount B is still under consideration.
- N/A (selected)
- N/A (selected)
Thailand has not yet established any legislations in this area as of September 2025.
Legal ReferenceThailand’s tax treaty network [LINK] Thailand’s MLI Position [LINK] No. 12, Paragraph 2 of the Notification of Director-General of the Revenue Department on Income Tax No. 400 (B.E.2564) dated 14 January 2021 [LINK]
Legal ReferenceSection 71 Bis of the Revenue Code [LINK] [LINK]
Yes. Year-end adjustments are allowed.
Legal ReferenceNo.12 of the Notification of Director-General of the Revenue Department on Income Tax No. 400 (B.E.2564) dated 14 January 2021 [LINK]
Legal ReferenceThailand’s tax treaty network [LINK] Thailand’s MLI Position [LINK]
Article 7 as it read before 2010.
- Article 7 as it read before 2010. (selected)
- Article 7 as it reads after 2010. (not selected)
- Other (please provide additional details) (not selected)
Legal ReferenceThailand’s tax treaty network [LINK] Thailand’s MLI Position [LINK]
Legal ReferenceThailand’s tax treaty network [LINK] Thailand’s MLI Position [LINK]
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