Mazars in Thailand recently published its transfer-pricing (“TP”) brochure, which outlines the new TP documentation requirements effective from 1 January 2021. Thailand’s tax laws use the arm’s-length principle and impose penalties for failing to comply with the TP documentation and disclosure requirements. It is important for taxpayers to review their TP policies to ensure that they comply with the arm’s-length principle and are aware of the new rules, in order to avoid additional tax assessments and penalties. Mazars transfer pricing experts can provide, develop, and implement customised transfer pricing solutions that fit clients’ commercial and tax strategies and mitigate tax risks.

A global view on a business-critical, fast-evolving issue.
Transfer pricing (“TP”) plays a major role in every company with cross-border activities, including intra-group supply and service relationships and financial integration, as well group restructuring.
While the tax audit risks associated with transfer prices can be significant, there is also an opportunity for the tax-efficient structuring of transactions.
In order to help clients assess the risks adequately and utilize all possibilities for optimization, Mazars’ experts consider not only the Thai regulations, but the transfer-pricing regulations in the other countries involved as well. This is possible because Mazars can draw on the expertise of over 42,000 professionals in over 90 countries, and thus offer seamless cross-border support in all of the areas below related to transfer pricing:
  • TP reports and benchmarking studies
  • TP policy implementation
  • TP planning and structuring
  • TP compliance and documentation
  • Tax advisory services on specific TP issues
  • Support with tax audits related to TP issues
  • Justifying the transfer prices used to the tax authorities in the course of a tax audit


Organizations that span international borders are increasingly facing complex regulatory and tax issues in the different jurisdictions where they operate. Transfer pricing is at the top of the tax priority list for many mid-sized and large businesses, with an outsized impact on and business units. We offer a range of solutions for transfer pricing management so you can ensure compliance with local regulations. 

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