Revenue Department Reduces Fines for Late Submission of Disclosure Form

On September 9th, 2020, the Revenue Department announced a reduction in fines for businesses who submit the Transfer Pricing Disclosure Form (“Disclosure Form”) after the extended August 31st deadline. Businesses who exceed the deadline were previously subject to a fine of 200,000 baht; presently, they will be required to pay a fine of only 5,000 baht. The Disclosure Form must be filed online via the Revenue Department’s e-filing system by December 30th, 2020. 

Normally, the Disclosure Form must be filed within 150 days of the end date of the accounting period; however, due to the COVID-19 crisis, the Ministry of Finance extended the deadline for paper filing to August 31st, 2020. For online filing between January 2020 and January 2021, the Revenue Department prolonged the deadline from 150 days to 158 days after the last day of the accounting period. 

The Revenue Code Amendment Act (No.47) B.E. 2561 (2018) entered into force on January 1st, 2019. The amendment was designed to bring Thailand’s legal framework into compliance with international standards on how market price is determined, and to reduce opportunities for tax evasion between (legally) related entities within an enterprise. Any business with an annual turnover of at least 200 million baht, and which does not meet prescribed exemption conditions, must file a Disclosure Form– essentially, a report which shows the nature of transactions between related entities in each accounting period. The Disclosure Form is submitted with a business’s annual corporate income tax returns. Prior to the COVID-19 extensions, the first filing date for a transfer pricing disclosure form was May 30th, 2020 for the fiscal year ending December 31st, 2019, and August 28th, 2020 for the fiscal year ending on March 31st, 2020.

Revenue Department News
September 9, 2020
On Reducing Fines for Businesses that Submit the Disclosure Form Beyond the Deadline

The Revenue Department has reduced the fine for businesses that submit the Disclosure Form beyond the deadline from 200,000 baht to only 5,000 baht. The Disclosure Form must be filed via the e-Filing system by December 30, 2020. 

Mrs. Sommai Siriudomset, the Strategic Tax Consultant for the Energy Business Group, revealed that “the Revenue Department has stipulated that companies or juristic partnerships that are related and, according to the financial statements, have a total income of 200 million baht or more in the accounting period beginning on or after January 1, 2019, must submit the Disclosure Form for the first time within 150 days from the last day of the accounting period, or within August 31, 2020 (in the event that businesses receive an extension of the filing period). If businesses fail to submit the form within the deadline, businesses are obligated to pay a fine of no more than 200,000 baht. However, due to COVID-19, the Revenue Department shall reduce the fine from 200,000 baht to only 5,000 baht, which must only be filed via e-Filing by December 30, 2020.”

Mrs. Sommai Siriudomset added that “The Revenue Department has added a new channel to file the Disclosure Form by uploading an Excel template, which will make it convenient, quick, and easy for businesses who have to file the Disclosure Form. Taxpayers may download the Excel template for the Disclosure Form on the Revenue Department’s website,, under the e-Filing title.”

The Regulation of Transfer Pricing in Thailand

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Deadline Extension for Transfer Pricing Disclosure Form Submission