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Thailand's Transfer Pricing Legislation Submitted to National Assembly with 2019 Effective Date

The Thai Government submitted to the National Assembly on 5 June 2018 the draft legislation to formalize the country's transfer pricing regime. The draft legislation is mostly unchanged from the version approved by the Thai Cabinet earlier in the year (previous coverage), although there are a few important amendments. One of the key amendments is that the effective date of the new legislation is set for tax periods beginning on or after 1 January 2019 (instead of 2017), which would require that the first transfer pricing disclosure report for taxpayers with THB 30 million in annual related party transactions will be due by the end of May 2020 for the period ending 31 December 2019 (same as tax return deadline). It is also clarified that related party relationships and transaction must be included in the report regardless of whether a relevant party was related during the entire year.

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