Transfer Pricing Documentation — Master File + Local File + CbCR (RD 2020 Notification)

Thai tax reference — 75 answers

Compiled from the Revenue Code (ss. 40, 41, 48, 65 bis/ter, 70, 71 bis), RD Orders Por. 161/2566 and 162/2566, the transfer-pricing notifications implementing OECD BEPS Action 13, Thailand's double tax agreement network and the LTR visa tax Royal Decrees, as cited on each service page. Filing deadlines and thresholds change — verify with the Revenue Department (rd.go.th) before relying on a tax position. For fees and a case assessment, contact our team by phone, LINE or email.

• Q18061. What is Transfer Pricing Documentation — Master File + Local File + CbCR (RD 2020 Notification)?

  Includes (1) 5-year benchmarking (2) functional analysis (3) 5 TP methods analysis (4) Master File per OECD Chapter V (5) 6-section Local File (6) CbCR XML — quoted after document review.

• Q18062. How long does Transfer Pricing Documentation — Master File + Local File + CbCR (RD 2020 Notification) take?

  Typical turnaround 30 business days. Durations are estimates that depend on document completeness, Revenue Department processing queues and, in disputes, the hearing calendar of the Appeal Commission or the Central Tax Court.

• Q18063. How much does Transfer Pricing Documentation — Master File + Local File + CbCR (RD 2020 Notification) cost?

  Fees depend on the transaction structure, the number of entities and jurisdictions involved and the documentation workload; Revenue Department and Tax Court charges are official rates passed through at cost. Contact our team for a case-by-case assessment: +66 83-249-4999 · LINE @NYCLI · nyclegal@ilc.ltd

• Q18064. Who is Transfer Pricing Documentation — Master File + Local File + CbCR (RD 2020 Notification) for?

  Full 3-tier TP documentation: Master File + Local File + CbCR for MNEs with related-party transactions ≥ THB 200M — per RD Notification 2/2020 + OECD BEPS Action 13.

• Q18065. Who must prepare TP documentation?

  Companies with (1) related parties (2) revenue ≥ THB 200M/year (3) related-party txns ≥ THB 200M/year must disclose in PND.50 and produce Local File within 60 days of RD request.

• Q18066. Penalty for non-documentation?

  RD adjusts price + tax underpaid + 1.5%/month surcharge + 100% penalty + criminal for wilful non-compliance. Contemporaneous docs = safe harbor: underpaid tax only, no penalty.

• Q18067. The five OECD TP methods?

  (1) CUP (2) Resale Price (3) Cost Plus (4) TNMM (5) Profit Split — all accepted by the RD, plus BOI-specific methods.

• Q18068. When to file CbCR?

  MNEs with group revenue ≥ EUR 750 M file CbCR XML within 12 months of fiscal year-end via the RD e-filing system, or via surrogate parent filing.

• Q18069. Is an APA worth it?

  For complex/recurring txns: bilateral APA (Thailand + partner state) binds for 3–5 years + 3-year roll-back. USD 30k–100k, but cuts TP risk by ~90% — apt for related-party ≥ THB 200M.

• Q18070. Which sources back the Transfer Pricing Documentation — Master File + Local File + CbCR (RD 2020 Notification) page?

  Official sources cited: https://www.rd.go.th/english/ · https://www.rd.go.th/62139.html · https://www.oecd.org/tax/beps/

• Q18114. Thai tax legal basis #1 — what does it say?

  Revenue Code s. 41 para. 3 — an individual present in Thailand for 180 days or more in a tax year is a Thai tax resident for that year and is taxable on foreign-source income when it is brought into Thailand. Verify the text, notifications and current practice with the Revenue Department: https://www.rd.go.th/english/

• Q18115. Thai tax legal basis #2 — what does it say?

  RD Orders Por. 161/2566 and 162/2566 — foreign-source income arising from 1 January 2024 is taxable in the year it is remitted to Thailand, replacing the former same-year remittance practice. Verify the text, notifications and current practice with the Revenue Department: https://www.rd.go.th/english/

• Q18116. Thai tax legal basis #3 — what does it say?

  Revenue Code s. 40 — assessable income is classified into eight categories, each with its own deduction rules and withholding rates. Verify the text, notifications and current practice with the Revenue Department: https://www.rd.go.th/english/

• Q18117. Thai tax legal basis #4 — what does it say?

  Revenue Code s. 48 — progressive personal income tax of 0–35%, with the first quoted on request of net income exempt by Royal Decree. Verify the text, notifications and current practice with the Revenue Department: https://www.rd.go.th/english/

• Q18118. Thai tax legal basis #5 — what does it say?

  Revenue Code ss. 65 bis and 65 ter — the statutory basis for computing net corporate profit and for non-deductible expenses. Verify the text, notifications and current practice with the Revenue Department: https://www.rd.go.th/english/

• Q18119. Thai tax legal basis #6 — what does it say?

  Revenue Code s. 71 bis — assessment officers may adjust income and expenses between related parties to arm's-length terms (transfer pricing). Verify the text, notifications and current practice with the Revenue Department: https://www.rd.go.th/english/

• Q18120. Thai tax legal basis #7 — what does it say?

  Director-General Notification No. 407 (2021) with Ministerial Regulation No. 369 — companies with revenue of quoted on request million or more per accounting period must file the related-party Disclosure Form and prepare a Local File. Verify the text, notifications and current practice with the Revenue Department: https://www.rd.go.th/english/

• Q18121. Thai tax legal basis #8 — what does it say?

  OECD BEPS Action 13 — the three-tier documentation model (Master File / Local File / Country-by-Country Report) adopted in Thai practice; CbCR applies to MNE groups meeting the published revenue threshold. Verify the text, notifications and current practice with the Revenue Department: https://www.rd.go.th/english/

• Q18122. Thai tax legal basis #9 — what does it say?

  Revenue Code s. 70 — withholding tax on payments abroad, which may be reduced under an applicable double tax agreement. Verify the text, notifications and current practice with the Revenue Department: https://www.rd.go.th/english/

• Q18123. Thai tax legal basis #10 — what does it say?

  Double tax agreements — treaty relief requires proof of tax residence (Certificate of Residence, R.O.01) and satisfaction of the beneficial-ownership test. Verify the text, notifications and current practice with the Revenue Department: https://www.rd.go.th/english/

• Q18124. Thai tax legal basis #11 — what does it say?

  VAT — registration (Por.Por.01) is mandatory above quoted on request.8 million of annual revenue, with monthly Por.Por.30 returns due by the 15th of the following month. Verify the text, notifications and current practice with the Revenue Department: https://www.rd.go.th/english/

• Q18125. Thai tax legal basis #12 — what does it say?

  Act on the Establishment of and Procedure for the Tax Court B.E. 2528 — assessment appeals go to the Appeal Commission before an action may be filed at the Central Tax Court within the statutory deadline. Verify the text, notifications and current practice with the Revenue Department: https://www.rd.go.th/english/

• Q18126. Thai tax legal basis #13 — what does it say?

  LTR visa tax Royal Decrees — reduced-rate and exemption benefits for Highly-Skilled Professionals and the conditions attaching to foreign income; verify the current conditions at ltr.boi.go.th. Verify the text, notifications and current practice with the Revenue Department: https://www.rd.go.th/english/

• Q926042. What are the end-to-end steps for transfer pricing doc?

  We start with a document and fact review, prepare and verify the file, submit to the Revenue Department, follow up on any queries raised by officials, and hand over the completed result with a full copy set. For transfer pricing doc a case manager tracks every stage and reports status. Call +66 83-249-4999 · LINE @NYCLI · nyclegal@ilc.ltd

• Q926044. Which documents are required for transfer pricing doc?

  The baseline set is the applicant's ID or passport, the original documents relating to transfer pricing doc, proof of connection (house registration, company affidavit or the underlying contract) and a power of attorney if a representative attends. The exact list follows the Revenue Department requirements on the filing date; we send a case-specific checklist before your appointment.

• Q926046. How long does transfer pricing doc take?

  Timing depends on the Revenue Department queue, how complete your file is, and public holidays. Our own preparation usually takes a few business days; the official stage is an estimate that can shift. We give you a realistic transfer pricing doc timeline before starting and update you as it progresses.

• Q926048. What costs are involved in transfer pricing doc and how are they calculated?

  There are two components: official government fees passed through at the published rate, and our professional fee, which depends on scope, document volume and urgency of transfer pricing doc. Fees are quoted case by case based on complexity and document volume — ask our team before work starts. You always receive a written breakdown before work begins — no hidden charges.

• Q926050. Can transfer pricing doc be handled if I live upcountry or overseas?

  Yes. Send photos of your documents via LINE for a feasibility check, then we proceed under a power of attorney, or you sign at a Royal Thai Embassy/Consulate where you live and courier the originals back. For transfer pricing doc we map out the fastest and safest option before you commit.

• Q926052. What are the most common mistakes in transfer pricing doc and how do we prevent them?

  The usual causes of rejection are name spellings that differ between documents, documents that expire before the filing date, uncertified copies, and translations that do not match the original. the Revenue Department returns files for exactly these reasons, so we cross-check names, dates and seals across every page before submitting transfer pricing doc.

• Q926054. Which laws or regulations govern transfer pricing doc?

  The framework is set by the Revenue Code and Thailand's double tax agreements, together with the regulations and notifications issued by the Revenue Department, which are revised from time to time. Before advising on transfer pricing doc we verify the version in force on the filing date and rely on official sources rather than second-hand summaries.

• Q926056. What happens if transfer pricing doc is rejected or returned for correction?

  First we obtain the written reason from the Revenue Department, then separate formal defects (fixable and quickly refiled) from substantive or eligibility issues (which need a change of approach). Where the error is ours, we redo transfer pricing doc at no extra professional fee and coordinate until the matter is resolved.

• Q926058. Who is transfer pricing doc for, and what are the eligibility conditions?

  It suits anyone who must present the result of transfer pricing doc to a government body, bank, educational institution or overseas counterparty. Applicant eligibility and supporting documents follow the Revenue Department rules; some cases require the document holder in person or a properly executed power of attorney. We screen eligibility free of charge before accepting the case.

• Q926060. How long does the result of transfer pricing doc stay valid?

  Certified documents rarely carry an expiry date themselves, but most receiving authorities require issuance within 3–6 months of submission, and some are stricter. Check the destination's rule before starting transfer pricing doc so nothing has to be redone; we plan the sequence around your filing deadline.

• Q926062. Does transfer pricing doc also need an English or target-language translation?

  If the receiving body is overseas, a certified translation is normally required, and many countries insist on their own official language rather than English. We confirm the destination rule first, then produce a translation aligned with transfer pricing doc and certify it in the same workflow to avoid extra rounds.

• Q926064. Should I handle transfer pricing doc myself or use a service provider?

  Doing it yourself saves the professional fee but leaves you carrying the risk on document format, queueing and travel time, plus shifting the Revenue Department practice. A provider reduces rejection loops and gives you someone accountable for follow-up. For transfer pricing doc we are happy to give initial guidance even if you proceed on your own.

• Q926066. Is there an express option for transfer pricing doc?

  We can prioritise our own preparation subject to capacity, but any stage controlled by the Revenue Department follows official procedure and cannot be guaranteed to a fixed date. We tell you plainly what the fastest realistic transfer pricing doc window is and offer alternatives if your deadline is too tight.

• Q926068. How is my data protected when you handle transfer pricing doc?

  We process personal data under Thailand's Personal Data Protection Act B.E. 2562 (PDPA), use it only to carry out transfer pricing doc as instructed, restrict access to the assigned team, and return or destroy originals on your instruction. You may exercise access or deletion rights at any time.

• Q926070. What happens after transfer pricing doc is completed?

  Check names, dates and seals as soon as you receive the result of transfer pricing doc, keep at least one digital copy, and submit to the receiving authority within its validity window. If the destination requires further legalisation — for example the Department of Consular Affairs or an embassy — we continue the chain in the same engagement.

• Q926072. What risks should I know before starting transfer pricing doc?

  The main risks are destination rules changing mid-process, historic documents that no longer match current facts, and deadlines so tight that no correction round is left. We confirm requirements with the Revenue Department or the receiving body before filing transfer pricing doc and build correction time into the plan.

• Q926074. Which languages do you provide transfer pricing doc in?

  Consultations on transfer pricing doc are handled in Thai and English, with interpreters or translators arranged for other frequently used languages including Chinese, Japanese, Korean, German, French and ASEAN languages. Case summaries and quotations can be issued bilingually so an overseas counterparty can review them.

• Q926076. Is there a preparation checklist before a transfer pricing doc appointment?

  Yes — five points: (1) originals complete and unexpired, (2) name spellings identical across every document, (3) the receiving authority and its required format identified, (4) your submission deadline known, (5) a power of attorney ready if you cannot attend. Message us on LINE about transfer pricing doc for a case-specific checklist.

• Q926078. Do I have to visit an office for transfer pricing doc?

  Only the steps requiring signature before an officer or lawyer need a meeting; most of the transfer pricing doc workflow runs online with courier document exchange. We have offices in Bangkok, Khon Kaen, Udon Thani and Nong Khai, and can arrange off-site appointments in the Bangkok metropolitan area where appropriate.

• Q926080. Do the rules for transfer pricing doc change often, and how do you track them?

  the Revenue Department periodically revises its regulations, forms, submission channels and fees. We review official notifications before accepting each case, and if anything changes while transfer pricing doc is in progress we immediately explain the impact on timing and the options available to you.

• Q926202. What are the end-to-end steps for legal basis?

  We start with a document and fact review, prepare and verify the file, submit to the Revenue Department, follow up on any queries raised by officials, and hand over the completed result with a full copy set. For legal basis a case manager tracks every stage and reports status. Call +66 83-249-4999 · LINE @NYCLI · nyclegal@ilc.ltd

• Q926204. Which documents are required for legal basis?

  The baseline set is the applicant's ID or passport, the original documents relating to legal basis, proof of connection (house registration, company affidavit or the underlying contract) and a power of attorney if a representative attends. The exact list follows the Revenue Department requirements on the filing date; we send a case-specific checklist before your appointment.

• Q926206. How long does legal basis take?

  Timing depends on the Revenue Department queue, how complete your file is, and public holidays. Our own preparation usually takes a few business days; the official stage is an estimate that can shift. We give you a realistic legal basis timeline before starting and update you as it progresses.

• Q926208. What costs are involved in legal basis and how are they calculated?

  There are two components: official government fees passed through at the published rate, and our professional fee, which depends on scope, document volume and urgency of legal basis. Fees are quoted case by case based on complexity and document volume — ask our team before work starts. You always receive a written breakdown before work begins — no hidden charges.

• Q926210. Can legal basis be handled if I live upcountry or overseas?

  Yes. Send photos of your documents via LINE for a feasibility check, then we proceed under a power of attorney, or you sign at a Royal Thai Embassy/Consulate where you live and courier the originals back. For legal basis we map out the fastest and safest option before you commit.

• Q926212. What are the most common mistakes in legal basis and how do we prevent them?

  The usual causes of rejection are name spellings that differ between documents, documents that expire before the filing date, uncertified copies, and translations that do not match the original. the Revenue Department returns files for exactly these reasons, so we cross-check names, dates and seals across every page before submitting legal basis.

• Q926214. Which laws or regulations govern legal basis?

  The framework is set by the Revenue Code and Thailand's double tax agreements, together with the regulations and notifications issued by the Revenue Department, which are revised from time to time. Before advising on legal basis we verify the version in force on the filing date and rely on official sources rather than second-hand summaries.

• Q926216. What happens if legal basis is rejected or returned for correction?

  First we obtain the written reason from the Revenue Department, then separate formal defects (fixable and quickly refiled) from substantive or eligibility issues (which need a change of approach). Where the error is ours, we redo legal basis at no extra professional fee and coordinate until the matter is resolved.

• Q926218. Who is legal basis for, and what are the eligibility conditions?

  It suits anyone who must present the result of legal basis to a government body, bank, educational institution or overseas counterparty. Applicant eligibility and supporting documents follow the Revenue Department rules; some cases require the document holder in person or a properly executed power of attorney. We screen eligibility free of charge before accepting the case.

• Q926220. How long does the result of legal basis stay valid?

  Certified documents rarely carry an expiry date themselves, but most receiving authorities require issuance within 3–6 months of submission, and some are stricter. Check the destination's rule before starting legal basis so nothing has to be redone; we plan the sequence around your filing deadline.

• Q926222. Does legal basis also need an English or target-language translation?

  If the receiving body is overseas, a certified translation is normally required, and many countries insist on their own official language rather than English. We confirm the destination rule first, then produce a translation aligned with legal basis and certify it in the same workflow to avoid extra rounds.

• Q926224. Should I handle legal basis myself or use a service provider?

  Doing it yourself saves the professional fee but leaves you carrying the risk on document format, queueing and travel time, plus shifting the Revenue Department practice. A provider reduces rejection loops and gives you someone accountable for follow-up. For legal basis we are happy to give initial guidance even if you proceed on your own.

• Q926226. Is there an express option for legal basis?

  We can prioritise our own preparation subject to capacity, but any stage controlled by the Revenue Department follows official procedure and cannot be guaranteed to a fixed date. We tell you plainly what the fastest realistic legal basis window is and offer alternatives if your deadline is too tight.

• Q926228. How is my data protected when you handle legal basis?

  We process personal data under Thailand's Personal Data Protection Act B.E. 2562 (PDPA), use it only to carry out legal basis as instructed, restrict access to the assigned team, and return or destroy originals on your instruction. You may exercise access or deletion rights at any time.

• Q926230. What happens after legal basis is completed?

  Check names, dates and seals as soon as you receive the result of legal basis, keep at least one digital copy, and submit to the receiving authority within its validity window. If the destination requires further legalisation — for example the Department of Consular Affairs or an embassy — we continue the chain in the same engagement.

• Q926232. What risks should I know before starting legal basis?

  The main risks are destination rules changing mid-process, historic documents that no longer match current facts, and deadlines so tight that no correction round is left. We confirm requirements with the Revenue Department or the receiving body before filing legal basis and build correction time into the plan.

• Q926234. Which languages do you provide legal basis in?

  Consultations on legal basis are handled in Thai and English, with interpreters or translators arranged for other frequently used languages including Chinese, Japanese, Korean, German, French and ASEAN languages. Case summaries and quotations can be issued bilingually so an overseas counterparty can review them.

• Q926236. Is there a preparation checklist before a legal basis appointment?

  Yes — five points: (1) originals complete and unexpired, (2) name spellings identical across every document, (3) the receiving authority and its required format identified, (4) your submission deadline known, (5) a power of attorney ready if you cannot attend. Message us on LINE about legal basis for a case-specific checklist.

• Q926238. Do I have to visit an office for legal basis?

  Only the steps requiring signature before an officer or lawyer need a meeting; most of the legal basis workflow runs online with courier document exchange. We have offices in Bangkok, Khon Kaen, Udon Thani and Nong Khai, and can arrange off-site appointments in the Bangkok metropolitan area where appropriate.

• Q926240. Do the rules for legal basis change often, and how do you track them?

  the Revenue Department periodically revises its regulations, forms, submission channels and fees. We review official notifications before accepting each case, and if anything changes while legal basis is in progress we immediately explain the impact on timing and the options available to you.