What are the transfer pricing rules in Thailand?
The Revenue Department has the power to make assessments regarding transfer of assets, rendering of services or lending of money without any compensation, service charge or interest, or with compensation, service charge or interest in an amount considered to be lower than the market value, without justification. Under transfer pricing regulations, the term “market price” is defined as the price of the remuneration, service fee, or interest which each independent party shall set fairly in business practice, in the transfer of assets, provision of services, or extension of loans of the same type as on the date of such transfer of assets, or provision of services, or extension of loans. The term “independent party” means a party to the contract that has no relationship with the other party in the aspects of management, control, or joint investment, directly or indirectly. Additionally, the Revenue Department has the power to determine the price of imported goods by comparing them with the
