HLB Thailand is the Thailand correspondent for

the prestigious International Tax Review

Dear Clients,

The Thai Revenue Department is placing Transfer Pricing at the centre of its audit agenda. Reviews are becoming more frequent, more data-driven, and increasingly focused on whether pricing outcomes of related party transactions genuinely reflect commercial reality.

Today, Transfer Pricing goes beyond documentation. It is about protecting margins, minimising penalty exposures, and confidently defending related-party transactions before issues escalate.

Why Transfer Pricing Audit Readiness Matters

With heightened scrutiny, transfer pricing reviews are now more targeted and technical. Businesses must ensure that their pricing policies for related party transactions align with operational substance.

Being audit-ready allows companies to:

• Identify risk areas early – recurring losses, volatile margins, BOI expiry impacts, or business restructuring outcomes

• Align operations with Transfer Pricing models – ensuring functions, assets, and risks (FAR) and reflect real business activity

• Reduce audit and penalty exposure – well-supported pricing of related party transactions 

• Substantiate related-party payments – management fees, royalties, and financing arrangements must pass arm’s length and benefit tests analysis

Key Areas The Revenue Department Focuses On

During reviews, The Revenue Department commonly examines:

• Profitability trends and recurring losses or inconsistent performance

• Potential value leakage through related-party payments

• Intercompany financing arrangements

• Whether limited-risk entities earn appropriate margins

• Consistency between Transfer Pricing documentation and Transfer Pricing Disclosure Forms

Failure to address these areas may result in Transfer Pricing adjustments, penalties, and surcharges on underpaid tax.

How HLB Thailand Can Support

Our Transfer Pricing specialists assist with:

• Transfer Pricing risk assessments and audit readiness reviews

• Review and Enhancement of Transfer Pricing documentation and benchmarking

• Strategic support during the Transfer Pricing audits and discussions

Be Prepared. Reduce Risk. Stay Compliant.

MEET OUR LEADERS

Andrew Jackomos

Senior Tax Partner

With decades of deep-rooted tax experience across Asia, Andrew is the go-to advisor for intricate international tax structures and regulatory compliance.

Amit Bhalla

Principal, Transfer Pricing

Specializes in transfer pricing consulting, advising multinational groups on strategizing intragroup transactions' pricing, statutory compliance, and tax-efficient business models across jurisdictions

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Want to read more insights like this?

Any questions?

If you would like to know more about the topics covered above please contact your HLB adviser or click here to send us your questions.

Kind regards,

HLB Thailand

www.hlbthai.com

HLB Thailand is a member of HLB International, the global network of advisory and accounting firms, operating in over 150 countries and with more than 1,000 offices worldwide. HLB is a member of the Forum of Firms (FoF), the association of international networks of accounting firms promoting consistent and high quality standards of financial and auditing practices world-wide.