Countries all over the world are applying greater scrutiny – and calling for stricter regulations – on transfer pricing practices.  However, this greater scrutiny can provide an opportunity to identify more cost effective arrangements for your international transactions.

In Thailand, the transfer pricing regime is placing greater burden on the company to report that the related party pricing is arm’s length and is supported by good quality transfer pricing documentation. Failure to have adequate transfer pricing documentation can result in higher tax penalties.

At a global level, there has been a rapid introduction of new transfer pricing regulations from the Organisation for Economic Cooperation and Development (OECD), particularly on intellectual property as part of their Base Erosion and Profit Shifting Initiative (BEPS). This will have a substantial impact on current and future transfer pricing structures for all sizes of business.

BDO Thailand’s Transfer Pricing Practice helps groups navigate this fast changing transfer pricing environment. Aided by dedicated transfer pricing practitioners around the BDO network, we provide a range of planning, compliance, audit defence and benchmarking services. We can work with you to develop transfer pricing policies that are defensible, flexible and in line with your overall tax planning strategies.

Our Transfer Pricing team can help you with:

• Preparing transfer pricing documents in accordance with legislation.
• Assist with the preparation and review of disclosures made to the revenue department.
• Working holistically to understand the future strategy of your business and to design an optimal transfer pricing structure.
• Assisting to respond to a risk review/audit including strategy advice, drafting letters and meeting with the department of business development.