International business transactions have increased dramatically over the years. Investment has increasingly expanded at an unprecedented rate in many countries. These international business activities have led to the formation of a group of companies with mutual interests which is known as "multinational enterprise" (MNE). Companies within the MNE may trade goods or services with one another by means of "Transfer Pricing".

The Revenue Department is aware of practical problems in calculating the market price. Therefore, the booklet "Determination of Market Price for Multinational Enterprises" is accordingly written to provide businesses with guidelines in determining acceptable market prices in accordance with international principles. The preparation of adequate documentation will save time and reduce the burden of proof on the market price to the Revenue Department.

This booklet comprises of four parts. Part I describes related tax laws in determining the market price. Part II explains methodologies in calculating the market price, whilst Part III provides process in establishing the market price. Lastly, the list of documentation that should be kept is suggested in Part IV.

The Revenue Department of Thailand
June 2002