The Revenue Code Amendment Act to introduce specific transfer pricing provisions into the income tax law (No. 47) was published in the Royal Gazette on November 21, 2018, and therefore has become law.
Specific transfer pricing provisions will apply to accounting periods starting on or after January 1, 2019. Once in effect, Thailand's income tax law will contain a definition of the arm's-length principle and introduce penalties for failure to comply with the transfer pricing disclosure requirement, in addition to the penalties for failure to comply with Thailand transfer pricing rules.