The corporate tax rate in Thailand is 20% (15% for small companies).
To prevent the evasion of taxation caused by manipulated transfer pricing within the MNEs, tax authorities can price goods and services by applying the provisions of Section 65 bis (4) (7), Section 65 ter, and Section 70 ter under the Revenue Code, Double Tax Agreements between Thailand and other countries, as well as Standard Accounting No. 37 and 47. Moreover, the Revenue Department recently issued Departmental Instruction No. Paw 113/2545, – Subject : Corporate Income Tax – The Determination of Transfer Price based on the Market Price, in order to provide tax officials with a standardized guideline on how to determine the transfer price based on the market price.