Content area
Abstract
The Revenue Department of Thailand (RD) views transfer pricing that takes place by the MNE as the process of trading goods or services with other multinational enterprise (MNE) members. Paw 113/2545, a RD departmental instruction entitled Corporate Income Tax - The Determination of Transfer Price based on Market Price, was issued in order to provide tax officials with a standardized guide on how the taxpayer is to determine the transfer price based on market price. Clause 2 seeks to define the term "transfer pricing methodologies which are accepted internationally." Clause 3 provides a four-step procedure that the taxpayer is to follow in establishing the market price. The RD describes the process of "Establishing the Market Price". Departmental Instruction No. Paw 113/2545 empowers officers of the RD to adjust the company's revenue and expenses when calculating the Corporate Income Tax through an audit. The RD accepts the following transfer pricing methods: Comparable Uncontrolled Price Method, Resale Price Method, Cost-plus method, and other transfer pricing methods.