Transfer Pricing 22 Nov 2025

108. Transfer pricing transaction of share service vs tax penalty risk

 

Transfer pricing transactions of share service In Thailand country from parent company or related Co.

Inland revenue department in the world (included Thailand revenue department  "TRD") view as same is the Base Erosion and Profit Shifting “BEPS” or tax evasion in worst case.

 

Taxpayer’s company shall be preparing in advance (My experience Q&A with Revenue officers)  for corporate penalty tax mitigation from Share service transactions. My experience guideline in Group CFO’s, Transfer pricing advisor and CPA summary as,    

 

Group A  How-to charging  

1. Principle/Reasonable under arm’s length principle.
2. How to calculate under OECD's guideline.
3. Arm’s length comparable and documents supporting.
4. Outcome and service transferred by job, monthly, Quarter and Yearly under contract.

 

Group B Substance over form

1. Contract/Agreement design as similar to third party suppliers.
2. Price comparable and evidence supporting.
3. Service outcome and evidence support them jobs.
4. Price adjustment by periods or agreement.
5. Payment plan and paid documents filling.

 

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