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Thailand transfer pricing documentation guide

March 11, 2008



Stuart Simons and Sangravee Thaidamri of Deloitte's transfer pricing team in Bangkok report on the transfer pricing documentation rules in Thailand

The Thai transfer pricing laws are contained in Sections 65 ter and 65 bis of the Thai Revenue Code and provide the Thai Revenue Department with the power to make pricing adjustments if transactions are not determined in accordance with market prices. These provisions, however, do not contain any transfer pricing documentation requirements.

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