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Current Direction and Trend of Transfer Pricing Audit

The Thai Revenue Department (“TRD”) has officially enacted transfer pricing laws in Thailand, which have been effective since fiscal year 2019. Consequently, the TRD has received transfer pricing disclosure forms from companies engaging in intercompany transactions. With the continuous development of the TRD’s internal information technology system, the TRD can analyze and select taxpayers to conduct transfer pricing audit more efficiently. Accordingly, it is essential for taxpayers to develop an awareness of the direction and trend of transfer pricing audit to manage possible transfer pricing risks associated with intercompany transactions.

This seminar will discuss transfer pricing audit cases, the type of intercompany transactions selected by the TRD for transfer pricing audit, and in-depth information on how to prepare in case of transfer pricing audit. The topics included in this seminar are as follows:

• Current direction and trend of transfer pricing audit
• Criteria for selecting a taxpayer for transfer pricing audit and the transfer pricing audit process
• Type of transfer pricing audit cases experienced by KPMG transfer pricing professionals and other related tax issues under the Thai Revenue Code and Customs Duty
• Negotiation with the TRD during the transfer pricing audit