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Thailand Extends Transfer Pricing Deadlines

12th April 2022

Thailand’s transfer pricing legislation has been in effect since 2019, and most of the newish laws coincide with OECD guidelines (master file, local file, and country-by-country report). However, there are a few exceptions. The master file requires the usual big-picture overview of the multinational group, but it also mandates some additional information about key clients and competitors. Also, more companies have to file the country-by-country report, as Thailand’s threshold is an annual consolidated revenue threshold of THB 500 million—that’s roughly €740 million, a little lower than the €750 million recommended by the OECD. But that seems like a minor detail given Thailand’s deadline to submit the country-by-country report: While the OECD’s recommendation for submission—followed by most countries—is 12 months after the ultimate parent entity’s fiscal year end, Thai Revenue’s legislation mandates that you file with the corporate tax return, within 150 days after the fiscal year end. A tight turnaround to say the least. If you think that deadline is a tough pill to swallow, here’s some surprising news: Thai Revenue seems to agree. Thai Revenue’s Ministry of Finance issued a notice extending the deadline to match the OECD’s: 12 months after the year-end. Should Thai Revenue request the report, however, you’ll only have 60 days to turn it in. The tax authority’s goodwill doesn’t stop there: On March 25, they extended deadlines for the relatedparty disclosure forms, too: Companies filing for accounting periods between January 1, 2020, and December 31, 2020, now have until May 30, 2022—a big difference from the original 150 days from the accounting year end.