In order 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. The Departmental Instruction is divided into the following sections.

1. Criteria for the Calculation of Net Profits of Juristic Partnerships or Corporations for Income Tax Purposes
2. Assessment of Revenue and Expenses Based on the Market Price
3. Methodologies in Determining the Market Price
4. Documentation that should be prepared
5. Advance Pricing Arrangements (APAs)

Part II - Methodologies in Calculating the Market Price