Thailand requires transfer pricing disclosures to be filed online

By Paul Ashburn & Rohit Sharma of HLB Advisory (Thailand) Ltd.

The Director-General of Thailand’s Revenue Department has issued a notice making it mandatory for companies to submit their transfer pricing disclosure forms online unless they have reasonable grounds for filing a paper form.

The notification, issued on 14 January,  is effective for accounting periods commencing on or after 1 January 2020. 

Many companies in Thailand adopt a 31 December year-end and will need to follow the notification when filing a disclosure form for the 31 December 2020 year.

Only companies with Baht 200 million (USD 6.7M) or more in revenues in an accounting period must file the disclosure form with the Thailand revenue department, disclosing details of their transactions during the year with related parties.

Companies must register to submit the form online. Registration and filing of the form must be done through the Thailand revenue department’s website, either directly or via the Ministry of Finance’s “Tax Single Sign-On” system.

The form will be considered submitted when the taxpayer receives a reference number from the online filing system.

If a disclosure form is filed by paper it must be accompanied by a letter explaining the reasons why the company cannot submit the form online.

Compulsory online filing of transfer pricing forms will greatly enhance the Thailand revenue department’s ability to review and analyse the information disclosed in the forms and assist in selecting taxpayers for transfer pricing audits.

The official notification is available in the Thai language. 

— Paul Ashburn is a Co-Managing Partner at HLB Thailand.

— Rohit Sharma is Principal, Transfer Pricing at HLB Thailand.