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Tax Advisory

Tax Advisory & Transfer Pricing

MMN can help plan and review compliance for corporate income tax, personal income tax, VAT and withholding tax, prepare transfer pricing documentation, use BOI tax incentives, and support you when the Revenue Department audits or asks for information — aiming for tax that is correct, documented and aligned with your business goals.

Who it’s for

Businesses that want tax to be planned, not a surprise

Growing SMEs

Plan before the year-end and keep monthly and annual filings consistently right.

Groups with related-party transactions

Set a transfer pricing policy and documentation consistent with the arm’s-length principle.

BOI-promoted or applying companies

Use tax incentives correctly within their conditions and keep promoted activities clearly separated in the accounts.

BOI service →

Owners & executives

Personal income tax planning, including remuneration and dividends from the company.

What’s included

How MMN can help with tax

01

Corporate & personal income tax planning

Review income, expenses and available deductions to plan correctly before the filing deadlines.

Corporate income tax →
02

VAT & withholding tax compliance review

Check output and input VAT and withholding, including double-tax-agreement points on payments abroad.

VAT →
03

Tax health-check

Review filed returns against the accounting records to find exposures and items to correct, in priority order.

04

Transfer pricing

Prepare the annual Disclosure Form and the Local File showing the arm’s-length analysis of related-party transactions.

Transfer pricing →
05

BOI tax incentives

Help compute and apply the tax incentives under your promotion certificate and keep promoted activities separated in the accounts.

BOI incentives →
06

Revenue Department audits & enquiries

Help review the issues, prepare explanations and documents, and attend meetings with officers alongside you.

WHT & DTAs →
Transfer pricing at a glance

The main transfer pricing duties

Related-party transactions should be on arm’s-length terms; the Revenue Department may adjust income or expenses where commercial or financial conditions differ from those between independent parties in circumstances indicating a transfer of profits (section 71 bis). Companies may also have reporting and documentation duties under section 71 ter.

Two different documents
  • Disclosure Form: companies with revenue exceeding THB 200 million in the accounting period (Ministerial Regulation No. 370) that have related parties under section 71 bis file the report with PND.50 within 150 days of the year-end.
  • Local File: prepared and provided on request — within 180 days for the first notice; subsequent notices within 60 days — the deadline may be extended, but not beyond 120 days from receipt of the notice (section 71 ter).
Read the full transfer pricing chapter →
How we work

From data to a tax plan you can act on

1

Understand the business

Gather the business model, shareholding, key transactions and filed returns.

2

Assess risks & opportunities

Identify exposures and the reliefs the law provides, then prioritise them.

3

Recommend with reasoning

Present options with the legal basis and documents required, so management can decide clearly.

4

Implement & monitor

Help put the plan into practice, file on time and revisit it when the law or the business changes.

Frequently asked questions

How is tax planning different from tax avoidance schemes?

Tax planning means using the reliefs and choices the law provides, backed by business substance and documentation. MMN does not advise on arrangements that lack business substance or contravene the law.

Which companies must file the transfer pricing Disclosure Form?

Companies or juristic partnerships with revenue exceeding THB 200 million in the accounting period (Ministerial Regulation No. 370) that have related parties under section 71 bis must file the report with PND.50 within 150 days of the year-end.

Can MMN help if we receive a letter from the Revenue Department?

Yes. MMN can help review the issues, prepare explanations and supporting documents, and attend meetings with the officers alongside you. The outcome depends on the facts and the officers’ assessment in each case.

What is a tax health-check?

A review of recently filed returns — such as corporate income tax, VAT and withholding tax — against the accounting records, to identify exposures, items to correct and reliefs that may not yet be used, summarised as a prioritised list.

Talk to us about your tax position

Tell us what tax questions your business is facing and we will help you decide what to tackle first.

Book a meeting

This page is general information for education only — not tax or legal advice for any specific case. Tax law and Revenue Department practice may change. Please consult MMN before making decisions or acting.