The reduction of the corporate income tax rate from 30 percent to 20 percent in 2013 has increased the Thai Revenue Department’s (TRD) focus on tax compliance and tax collection transfer pricing is one of the major audit areas by the TRD as the tax assessment can be significant. Based on the current practice, the transfer pricing issues are not limited to the taxpayers who are under the supervision of the Large Taxation Organization (LTO) at the TRD headquarters but also those under the supervision of the local tax offices could be questioned by the local tax authorities. KPMG in Thailand has observed more and more cases where the local tax authorities rather than the headquarters of TRD have questioned transfer pricing issues during their routine tax audits which may lead to detailed transfer pricing audits. There is an increase in investigations of inter-company service transactions.

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