Thailand Transfer Pricing Documentation Requirements
Thailand requires a Master File and Local File from entities with annual revenue above THB 200 million, produced within 60 days of a request, and a Transfer Pricing Disclosure Form is filed with the corporate tax return. The same revenue threshold governs both the documentation and the disclosure form.
Requirements at a glance
| Requirement | Threshold | Deadline | Deadline type | Language | Penalty |
|---|---|---|---|---|---|
Master File Required | Local entity annual revenue > THB 200m | On request | Preparation deadline The documentation must exist by the date shown and is produced only when the tax authority requests it. Once requested, it must be provided within 60 days. | TH | Yes (up to THB 200,000) |
Local File Required | Local entity annual revenue > THB 200m | On request | Preparation deadline The documentation must exist by the date shown and is produced only when the tax authority requests it. Once requested, it must be provided within 60 days. | TH | Yes (up to THB 200,000) |
TP Disclosure Form TPDF
Annual filing | Taxpayers with annual revenue ≥ THB 200m | With the corporate tax return | Submission deadline The documentation must be filed with the tax authority by the date shown. | TH | Yes |
CbC report Required | Group revenue ≥ THB 28,000m | 12 months after fiscal year-end | Submission deadline The Country-by-Country report is filed by the group's ultimate parent entity; a local notification identifying the reporting entity is filed separately. | — | Yes |
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Scope of the documentation obligation
The Master File and Local File requirement applies to a Thai entity with annual revenue exceeding THB 200 million. The same threshold governs the Transfer Pricing Disclosure Form, which, for financial years beginning on or after 1 January 2019, must be prepared by taxpayers reaching that revenue level. The documentation is produced within 60 days of a request from the tax authority.
Distinctive features of the Thai regime
The defining feature of the Thai regime is the Transfer Pricing Disclosure Form filed with the corporate tax return, which precedes and informs any request for the underlying documentation, giving the authority a structured view of a taxpayer’s related-party dealings before it asks for the files. A single revenue threshold of THB 200 million governs the documentation, the disclosure form, and the penalty exposure of up to THB 200,000 for failing to prepare or submit the documentation on request. There is no safe harbour, and the practice in audit leans toward aggregation, with the tax officer often focusing on the Thai entity’s bottom-line profit. An extended electronic filing window applies to both the return and the disclosure form during a defined relief period.
Benchmarking and comparables
There is no written rule on comparables, but in practice local comparables are requested and preferred. Three-year or five-year testing is commonly used. A new benchmarking search may be rolled forward for two years after the year in which it is conducted. The general limitation period is five years after the due date for filing the corporate income tax return.
Frequently asked questions
What is the Thai Transfer Pricing Disclosure Form?
It is a structured disclosure of related-party dealings, prepared by taxpayers with annual revenue of at least THB 200 million and filed with the corporate tax return, which informs any later request for the underlying Master File and Local File.
This guide is an informational research aid prepared by Comp-Press and is not tax or legal advice. Transfer pricing rules change; verify current requirements before relying on them for filing.