Accounting service
Check disclosure duties and organise pricing evidence for actual domestic and cross-border related-party transactions.
Check the filing entity's revenue, not group totals: strictly above THB200million plus a section71 bis relationship triggers section71 ter disclosure even without transactions or with a relationship during only part of the period. Ordinary filing is with PND.50 within 150 days after period-end; check applicable extensions separately. Documentation is not a universal annual attachment.
Need a scope assessment? Describe the accounting or tax issue, relevant periods and due dates so the checks, required records and responsibilities can be clarified before a meeting.
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Check the filing entity's revenue, not group totals: strictly above THB200million plus a section71 bis relationship triggers section71 ter disclosure even without transactions or with a relationship during only part of the period. Ordinary filing is with PND.50 within 150 days after period-end; check applicable extensions separately. Documentation is not a universal annual attachment. An ordinary notice allows 60 days, approved necessary-cause extension up to 120 total days from receipt, and a first notice 180 days as a separate branch. The reporting threshold does not exempt substantive pricing adjustments.
Quote-based — Quoted per engagement · Assessed after reviewing transactions and data readiness
If you handle it yourself
Incomplete records, an inapplicable rule or delayed approval can affect filing and tax payments. The issues below are review points for defining an engagement, not reports of any client's results.
Check the filing entity's own revenue and legal relationship tests: more than THB 200 million triggers disclosure with PND.50 when both tests apply. Exactly THB 200 million is within Regulation 370's exemption.
How we prevent it: Review entity revenue, ownership links and intercompany entries before agreeing the disclosure preparation scope.
Check adjustment powers, conditions and comparability evidence. A missing file alone does not establish a tax or surcharge amount.
How we prevent it: We prepare a Local File with a defensible comparability analysis.
How it works
Group transactions by type and value to see which carry adjustment risk.
Establish what the Thai company does, which assets it uses and which risks it bears.
Select independent comparables and compute the arm's length profit range.
File the disclosure form with the PND.50 and hold the Local File ready for any request.
Compare your options
| Aspect | Do it yourself | In-house staff | Work with us |
|---|---|---|---|
| Total annual cost | Looks free, but costs the owner's time and carries penalty risk | Assess actual payroll, employer contributions, software and cover arrangements rather than assuming one annual cost | Request a staff quotation that identifies scope and any additional items before agreement |
| Continuity | Stops the moment the owner gets busy | Staff turnover takes the institutional knowledge with them | Agree engagement owners, handover arrangements and traceable document storage |
| Review layer | Nobody double-checks | Self-review only, rarely an outside perspective | Preparer and reviewer within scope; audit work separately assigned to a CPA Partner (transfer pricing) |
| When the Revenue Department calls | You attend and answer alone | In-house staff rarely have hearing experience | Prepare evidence and explanations within scope; attendance depends on authorization and taxpayer duties |
An adviser, not just a filer
Separate disclosure data from transaction analysis. Review functions, assets, risks and comparability methods against actual evidence and flag gaps. A Local File does not guarantee acceptance of prices or immunity from tax adjustment.
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FAQ
No. Regulation370 exempts section71 ter duties at revenue not exceeding THB200million, including equality, but does not erase section71 bis adjustment conditions and powers. Check relationship and commercial/financial terms differing from independent dealings in a manner suggesting profit transfer; this is not automatic adjustment of every entity or transaction. Consider the scope of RD Por.113/2545 market-price rules separately.
Yes. Section71 bis includes direct or indirect holdings of not less than50%, and the common-holder branch meeting that level in both entities. Check actual capital and structure, not just shared director names. Capital, management or control is a separate branch under applicable rules; domestic-only dealings do not remove the relationship test.
For entities required to file, submit with PND.50 within the ordinary 150 days after period-end. Check extensions and conditions applicable to the filer; using an online system does not itself establish extra time.
Section 35 ter provides a fine of up to THB 200,000 for failing to file the form or to produce requested documents without reasonable cause.
CbCR has separate consolidated-group thresholds and filing conditions. Check the parent, residence and information-exchange arrangements before concluding the Thai entity duty.
You can respond with your documentation, and where the other country has a tax treaty with Thailand you can request the mutual agreement procedure (MAP) to relieve double taxation.
Check lender, borrower, relationship, currency, term, security and terms independent parties would agree. Zero interest alone does not determine the tax adjustment or a benchmark rate. Retain contracts, cash-flow evidence and comparables; withholding and treaty conditions require separate assessment.
You need to show the Thai company actually received and benefited from the services — reports, emails, meeting notes and a reasonable allocation key. Without that evidence the RD may disallow the expense, and fees paid abroad also need withholding tax and PP.36 checks.
Exactly THB 200M remains exempt under Regulation 370. Above this amount, check the statutory relationship conditions; zero transactions do not remove a qualifying relationship. The test uses filer revenue rather than the group total.
These are separate duties: annual disclosure versus documentation on written request. Section 71 ter normally allows 60 days; an approved extension cannot exceed 120 days from receipt. The first request allows 180 days, not a recurring 180-day extension.
These original sources address the issues described under each reference; they do not certify every statement or a service outcome. Check amendments and the conditions applicable to the entity's actual circumstances.
1. Guidance
Revenue Code: sections 71 bis and 71 ter on transfer pricingThe Revenue Department
Relationships, arm's-length rules and requests: normally 60 days, approved extension capped at 120 days from receipt; first notice 180 days. Revenue exemption is in Regulation 370.
2. Notification
Ministerial Regulation 370: section 71 ter exemption up to THB 200mThe Revenue Department
Sets the section 71 ter exemption at income not exceeding THB 200m; the revenue trigger is strictly above, not at least, THB 200m.
3. Guidance
Revenue Department: related-party disclosure instructionsThe Revenue Department
Total filer revenue above THB 200m, direct/indirect shareholding of at least 50% and form completion; group revenue does not replace entity revenue.
4. Guidance
RD Por.113/2545: market pricing and transfer-pricing evidenceThe Revenue Department
Income/expense adjustments and market-price comparison methods, separate from section71 ter reporting thresholds; not certification of a transaction price.
Scoped source check, not whole-page certification:
Deep-dive knowledge on this subject
The questions clients actually raise on this kind of engagement, answered with the deadlines, paperwork and penalty figures attached.
Related services
Review applicable tax relief, BOI conditions and treaty eligibility against the business facts.
View service detailsRecords and schedules ready so the independent auditor can finish before the shareholders' meeting.
View service detailsEnglish / Chinese support — BOI accounts, transfer pricing, treaty withholding.
View service detailsReal engagements
Revenue Code sections 71 bis and 71 ter require arm's-length pricing between related companies and a disclosure form with PND.50 for companies above the revenue threshold. Officers may later request pricing documentation
What owners ask before deciding
Continue by what you need to do next
Open a filing guide if you are submitting yourself, or a definition if a document name is still unclear.
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Authorities and terminology behind this page
These original sources address the issues described under each reference; they do not certify every statement or a service outcome. Check amendments and the conditions applicable to the entity's actual circumstances.
1. Code
The Revenue CodeThe Revenue Department
The governing text for income tax, VAT, specific business tax and stamp duty, together with the ministerial regulations and departmental instructions issued under it.
2. Notification
Royal Thai Government GazetteRoyal Thai Government Gazette
Where the authentic text of every act, decree, ministerial regulation and notification is published.
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