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title: "Before the Revenue Department Knocks: Is Your Transfer Pricing Defensible?"
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Businesses in Thailand must ensure their transfer pricing positions are clear, consistent, and defensible in a tax audit. ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­    ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­  

| View in browser 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.   Read our Transfer Pricing Services Brochure 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 Contact us Consistent Excellence: HLB Thailand Celebrates 5 Years of ITR Recognition HLB Thailand is delighted to be recognized, for the fifth consecutive year, as one of the most rapidly growing and efficient transfer pricing firms in Thailand by the International Tax Review (ITR). Read More Thailand’s Cabinet Approves Draft Secondary Legislation on Global Minimum Tax On 30 December 2025, the Thai Cabinet approved in principle four pieces of draft secondary legislation to support the implementation of Thailand’s Emergency Decree on Top-up Tax. Read More Tariffs and transfer pricing: the friction ramps up Amit Bhalla and Dean Rangel of HLB Thailand explore how rising global tariffs are disrupting transfer pricing arrangements, tested party selection, and benchmarking, with Thailand’s manufacturing sector facing increased pressure under shifting supply chains Read More Scanning intragroup royalty payments through the lens of the OECD’s BEPS projects Andrew Jackomos and Amit Bhalla of HLB Thailand examine how evolving global tax standards are reshaping the treatment of intragroup royalty payments and driving stricter compliance and documentation requirements. Read More In case you missed it..... Everything you’ve ever wanted to know about Transfer Pricing in Thailand (with examples) What’s the difference between a Master file and a Local file? Thai Revenue Department rules on companies’ relationship based on common shareholding Two-pillar framework: how is Thailand gearing up? How Do I Become Compliant in Transfer Pricing? Transfer pricing documentation requirements clarified Online filing of Transfer Pricing disclosure forms now mandatory Want to read more insights like this? Click to visit our website   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. 14th Floor, CTI Tower 191/70-73 New Ratchadaphisek Road, Klongtoey, Bangkok, Thailand 10110, +66 2 260 7290 Unsubscribe Manage preferences |
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