Taxpayers are well advised to prepare contemporaneous documentation indicating steps and rationale in determining  the market price during  each stage of a transaction, and retain them at their office.

The list of documentation which should be prepared and kept is as follows:

1. Documentation indicating the structure and relationship between business entities within the same group, including the structure and nature of business carried on by each entity;
2. Budgets, business plans and financial projections;
3. Documentation indicating taxpayers’ business strategies as well as the reasons for adopting such strategies;
4. Documentation indicating sales and operating results and the nature of its transactions with business entities within the same group;
5. Documentation indicating the reasons for entering into international transactions with business entities within the same group;
6. Pricing policies, product profitability, relevant market information and profit sharing of each business entity. Consideration should be given to functions performed, asset utilized and risks assumed of the related business entities;
7. Documentation supporting selection of a particular pricing method;
8. Where several methods are considered, documentation indicating details of the methods apart from the method stated in 7 and the reasons for rejection of these methods. These documents should be created at the same time the decision is made to select the method in 7;
9. Documentation used as evidence indicating the negotiation positions taken by the taxpayer in relation to the transaction with business entities within the same group and the basis for those negotiating positions;
10. Other related documentation in determining the transfer price (if any).

Note :    This translation is for those who are not familiar with the Thai language.  The Thai text is an official text.