Thailand’s country-by-country-report (CbCR) regulations follow the OECD’s CbCR rules under Action 13 of the base erosion and profit shifting (BEPS) project. Under Thailand’s CbCR rules, multinational enterprise (MNE) groups with consolidated group revenue of THB 28 billion (approximately EUR 750 million) or more in the preceding fiscal year must provide the information requested in the CbCR to the tax authorities.
In accordance with the Thai CbCR regulations, MNE groups with ultimate parent entities or surrogate parent entities in Thailand are required to submit the full CBCR to the Thai tax authorities through an electronic system within 12 months from the last day of the accounting period. In addition, MNE groups operating in Thailand must select a representative entity that is required to file a notification with the Thai tax authorities before the last day of the MNE group’s fiscal year.
The CbCR notification includes information regarding:
Thai companies with annual total revenue of more than THB 200 million are also required to submit a “Transfer Pricing Disclosure Form” within 150 days from the end of the fiscal year. Part C of the Disclosure Form requires the company to submit information about the CbCR, and to check a box confirming that the MNE group submitted the CbCR. The MNE also must provide the name and country of the ultimate or surrogate parent entity submitting the CbCR.
To summarize, the CbCR notification in Thailand is a two-step process. The first step involves submission of the notification through Part C of the Transfer Pricing Disclosure Form within 150 days after the fiscal year-end of the Thai entity. The second step is the submission of the CbC report within 12 months after the fiscal year-end of the MNE group.
If the Thai company receives a CbCR submission notice from the Thai tax authorities, it must submit the CbCR within 60 days from the date of receiving the notice.
Failure to file a required CbCR in a timely manner may result in a THB 2,000 fine.
The Thai transfer pricing regulations and reporting requirements follow the OECD regulations. In addition, the Thai tax authorities have issued local reporting requirements. It is critical that companies within the scope of the rules meet these deadlines and compliance requirements to avoid fines and penalties.
Ishan Shah
BDO in Thailand
In accordance with the Thai CbCR regulations, MNE groups with ultimate parent entities or surrogate parent entities in Thailand are required to submit the full CBCR to the Thai tax authorities through an electronic system within 12 months from the last day of the accounting period. In addition, MNE groups operating in Thailand must select a representative entity that is required to file a notification with the Thai tax authorities before the last day of the MNE group’s fiscal year.
The CbCR notification includes information regarding:
- The ultimate parent entity’s jurisdiction
- The ultimate parent entity’s tax identification
- The ultimate parent entity’s name
- The CbCR reporting entity
- The financial year
- A list of Thai group entities
Thai companies with annual total revenue of more than THB 200 million are also required to submit a “Transfer Pricing Disclosure Form” within 150 days from the end of the fiscal year. Part C of the Disclosure Form requires the company to submit information about the CbCR, and to check a box confirming that the MNE group submitted the CbCR. The MNE also must provide the name and country of the ultimate or surrogate parent entity submitting the CbCR.
To summarize, the CbCR notification in Thailand is a two-step process. The first step involves submission of the notification through Part C of the Transfer Pricing Disclosure Form within 150 days after the fiscal year-end of the Thai entity. The second step is the submission of the CbC report within 12 months after the fiscal year-end of the MNE group.
If the Thai company receives a CbCR submission notice from the Thai tax authorities, it must submit the CbCR within 60 days from the date of receiving the notice.
Failure to file a required CbCR in a timely manner may result in a THB 2,000 fine.
BDO Insights
The Thai transfer pricing regulations and reporting requirements follow the OECD regulations. In addition, the Thai tax authorities have issued local reporting requirements. It is critical that companies within the scope of the rules meet these deadlines and compliance requirements to avoid fines and penalties.Ishan Shah
BDO in Thailand