Transfer Pricing Documentation (Local + Master File)
Illustrative record preparation, not evidence of our staff, client records or authority approval.
เอกสาร Transfer Pricing (Local File + Master File) · § CrossBorder
What to know before you act
Start with statutory relationships and actual goods, services, royalty or loan transactions. Separate annual disclosure from supporting pricing evidence. Disclosure is a summary, not a full analysis. Records should explain functions, assets, risks and appropriate methods; no database or method guarantees acceptance.
Timing and external dependencies: Check disclosure duties against the PND50 date. For requested records, read the request and statutory extension or first-request rules; 60 days is not a universal deadline. Preparation depends on transactions and comparison data; no audit result is promised.
Official fee: Check current RD rules for any tax, surcharge, penalty or authority fee. These are separate from company service fees: Ask our team for a quotation.
Timing is not a promise of an outcome or hearing date. Check the notice, limitation period and current authority rules for your matter.
What to send for the first review
Send the accounting or tax period, filing deadline, transaction volume and work required. Separate routine filing from historical corrections and include prior returns. The free initial enquiry covers scope and quotation, not free legal advice or case analysis.
- Group, ownership and related-counterparty charts
- Statements, ledgers and transactions by counterparty
- Goods, service, licence or loan contracts and performance evidence
Legal Basis
Revenue Code Sections 71 bis and 71 ter concern legally related entities, reporting and supporting information. Check relationships, revenue criteria and exemptions. Local File, Master File and CbCR are not automatically concurrent duties for every company, and a single debt-to-equity ratio is not a universal rule.
📚 Official sources — check the current law and procedure before acting
Who Needs This
Entities with related domestic or overseas counterparties, Disclosure Form preparers and businesses receiving requests to explain intercompany prices or terms.
Required Documents
- Group, ownership and related-counterparty charts
- Statements, ledgers and transactions by counterparty
- Goods, service, licence or loan contracts and performance evidence
- Functions, assets, risks and pricing-policy descriptions
- Prior disclosures, group reports and official requests if any
Common Pitfalls
- Assuming no disclosure duty means no transaction evidence is needed
- Using a parent report without checking Thai entity coverage
- Choosing methods before understanding functions and risks
- Treating disclosure as submission of all supporting records
Document-review situations (not client histories)
- Evidencing benefits from group management services
- Explaining a manufacturer’s functions and risks on related sales
- Responding to an intercompany-loan information request
FAQ
- Can a domestic group be affected?
- Potentially yes. Statutory relationships are not limited to multinationals. Check the structure and the entity’s reporting criteria.
- Is Disclosure a Local File?
- No. Disclosure summarises relationships and transactions. Supporting analysis evidences prices and terms when required or requested by law.
- Does every company need Master File and CbCR?
- No. Check each requirement and the entity’s group role separately. Transfer pricing does not automatically require every package.
- Can a parent report or database be used unchanged?
- It can be a starting point. Check period, transactions, functions, risks and suitability for the Thai entity. No database provides automatic RD acceptance.
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Official sources — legal services
The information on this page follows the official sources below. Always check the latest version before you file.
- Office of the Judiciary— Office of the Judiciary
- Ministry of Justice— Ministry of Justice
- Lawyers Council of Thailand — Notarial Services Attorneys— Lawyers Council of Thailand
- Office of the Council of State — Thai law database— Office of the Council of State
- Royal Thai Government Gazette— Royal Thai Government Gazette
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Frequently asked questions
- Can a foreigner own 100% of a Thai company?
- Full foreign ownership is possible for some activities, but there is no blanket permission. Check the Foreign Business Act definition, actual activities, sector-specific restrictions and any required licence or certificate. BOI promotion and treaty rights apply only within their approved scope; they do not automatically confer land rights, visas or work permits. Do not use nominee shareholders. Verify the proposed structure with DBD.
- What is the minimum registered capital for a Thai company?
- Do not apply one capital figure to every incorporation, foreign-business licence, visa or work-permit application. Registered capital and paid-up capital are different, and the applicable requirements depend on actual activities, ownership, permit category and any BOI or treaty conditions. Capital is a company funding requirement, not our service fee. Confirm the relevant criteria with DBD, the Department of Employment and Immigration before choosing the structure. Ask our team for a quotation for the agreed work.
- How long does company registration take?
- Separate document preparation, name reservation, signatures and DBD review from VAT registration, Social Security and bank onboarding. Timing depends on the filing channel, complete documents and any requests for corrections or additional evidence; no completion date is guaranteed. Ask our team for a quotation and a planning estimate after the proposed structure and documents have been reviewed.
- What ongoing accounting obligations does a Thai company have?
- A Thai limited company keeps statutory books and prepares audited annual statements even without trading. Tax returns depend on its payments, VAT status, accounting period and taxpayer category: PND1, PND3 and PND53 are not universal monthly returns for every company, and PP30 applies to VAT-registered businesses, including nil-return months while registration remains active. Check PND50, PND51 and each filing deadline with RD; check annual statements and shareholder filings separately with DBD.