![]() ![]() ![]() Carefully evaluate Transfer Pricing methodology at or before the time of filing a tax return, and the compliance with the applicable Transfer Pricing rules.Prepare appropriate Transfer Pricing documentation.With these guidelines, the taxpayers are able to: These objectives provide guiding principles to both taxpayers and tax administrators. Provide tax administrations with useful information to employ in conducting an appropriately thorough audit of the Transfer Pricing practices of entities subject to tax in their jurisdiction, although it may be necessary to supplement the documentation with additional information as the audit progresses.Provide tax administrations with the information necessary to conduct an informed Transfer Pricing risk assessment.Ensure taxpayers give appropriate consideration to Transfer Pricing requirements, to establish prices and other conditions for transactions between associated enterprises, and in reporting the income derived from such transactions in their tax returns. In order to standardise the Transfer Pricing documentation process, the three-tiered approach aims to: ![]() The approach includes the preparation of three documents: Master File, Local File, and the Country-by-Country Report. Under Chapter V of the 2017 OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, a three-tiered approach to Transfer Pricing documentation has been incorporated for taxpayers with related party transactions. Understanding these changes is essential for taxpayers with related party transactions. In July 2017, the Organisation for Economic Co-operation and Development (OECD) incorporated and updated the guidelines on Transfer Pricing, aligning the recommendations from Action Plan 13 of the Base Erosion and Profit Shifting (BEPS) Inclusive Frameworks for Multinational Enterprises. Investment promotion and foreign business licenses.Company formation and business registration services.New rule for taxation of foreign income from.Employers must submit payroll tax returns via electronic channels only starting January 2024.Navigating Sustainability: IFAC’s Checklist Shared by HLB Thailand. ![]()
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