Introduction to THAILAND

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3 Introduction to THAILAND Thailand, the second largest economy in the ASEAN (Association of South East Asian Nations) recently crossed into upper middle-income status. Thailand has ample FX reserves, the fiscal policy stance is prudent and public debt is moderate. The current account surplus has widened and is significant, thanks to a sizable improvement in the terms of trade, soaring tourism, and a reduction in imports due to a drop in domestic demand. Thailand s financial markets have weathered repeated episodes of global financial volatility relatively well. Economic institutions are credible and solid. The short term outlook is favourable: the economy is set to grow at its fastest pace since 2012 (close to 4%) driven by investment and consumption. On the negative front, political risk is growing steadily. Political and social crises have not been resolved with any degree of finality. While the junta has talked about a return to democracy since it seized power in May 2014, it has repeatedly delayed elections. A new date has been set for February 2019, but the election is likely to be further postponed. Domestic politics may pose a risk to the current investment push and therefore hamper growth momentum. Over the medium term, Thailand s economic growth prospects continue to weaken. Thailand is vulnerable to variations in world trade, and more than ten years of political instability have made the country less attractive: infrastructure development has slowed and more generally the quality of the business environment has worsened. Little by little, the fall in Thailand s competitiveness has resulted in the shrinking of its market share in several key sectors, to the benefit of neighbouring countries. Summary BNP Paribas presence BNP Paribas has had a presence in Thailand since 1979, with a full branch license granted in The bank has a business centre located in Bangkok, and customers have access to over 145 branches. BNP Paribas provides comprehensive support for the domestic and cross-border cash management and international trade finance needs of both Thai companies operating internationally and foreign company doing business in Thailand. Working with BNP Paribas BNP Paribas is a member of the local clearing house and provides comprehensive payments, collections and cash management solutions. BNP Paribas is a major player in trade finance throughout Asia, offering a full suite of traditional trade (letters of credit, bankers guarantee, trade financing, standby letters of credit, etc.) and supply chain financing solutions (receivables purchase programmes, supplier financing etc.) products, including a unique inventory solution offered through its trade centres in Australia, China, Japan and Singapore, specifically for companies engaged in international trade, as part of a wider network of more than 100 trade centres globally. BNP Paribas has experienced trade finance advisors and personnel who deliver a range of customised trade solutions and advise on local market practices. These solutions are supported by the bank's ISO-certified trade services support team. Currency Currency Thai Baht (THB).

4 Exchange Rates Exchange rate: THB per USD Source: IMF, International Financial Statistics, June Central Bank The Thai central bank is the Bank of Thailand (BOT - Bank supervision Thai banks are supervised by the BOT. Bank accounts Resident / non-resident status A company incorporated in Thailand is considered a Thai resident. Bank accounts for resident entities Within Thailand Outside Thailand Local Currency Permitted without restriction, fully convertible Permitted with approval, fully convertible Foreign Currency Permitted without restriction, fully convertible Permitted without restriction, fully convertible Bank accounts for non-resident entities Within Thailand Outside Thailand

5 Local Currency Permitted without restriction, fully convertible Permitted without restriction, fully convertible Foreign Currency Permitted without restriction, fully convertible Not applicable Lifting fees Few lifting fees apply because of the difficulties making payments between resident and non-resident bank accounts. BNP Paribas insights Account opening in Thailand is relatively straightforward subject to standard compliance and know your customer (KYC) requirements; however, there are some restrictions on the use of accounts and permitted balances. Please contact your BNP Paribas Relationship Manager for more information. BNP Paribas Cash Management Capabilities Liquidity Management Physical cash pooling Notional pooling Supported by BNP Paribas Not required / permitted in THAILAND or not supported by BNP Paribas Collections Cash collections Cheque collections Direct debit collections Domestic incoming transfers

6 International incoming transfers Card acquiring Supported by BNP Paribas Not required / permitted in THAILAND or not supported by BNP Paribas Payments Cash withdrawals Cheque payments Direct debit payments Domestic outgoing transfers International outgoing transfers Card issuing Supported by BNP Paribas Not required / permitted in THAILAND or not supported by BNP Paribas Channels Local e-banking Global e-banking - Connexis SWIFTNet / Global host to host Supported by BNP Paribas

7 Not required / permitted in THAILAND or not supported by BNP Paribas Payments & Collections Market overview There is still a heavy reliance on cash and cheques in Thailand, although there is an efficient real-time gross settlement system (RTGS) and bulk payment system. A new cheque clearing system, including digital imaging of cheques, has reduced the clearing cycle and eliminate cheque transportation costs. Payment systems BAHTNET BPS Type Real-time gross settlement. Participants 65 participants. Transaction types processed High-value and urgent domestic THB-denominated credit transfers. Net obligations from Thailand s other payment systems. Operating hours 08:30-17:30, ICT Monday to Friday. Clearing cycle details (e.g. cut-off times) Payments are leared and settled in real time. Cut-off time = 17:30 ICT. System holidays BAHTNET is closed on all Thai bank holidays. Thailand s bank holidays are: 1. 2nd half 2018: 1, 26 July, 13 August, 23 October, 5, 10, 31 December : 1 January, 19 February*, 8, 13, 15, 16 April, 1, 20* May, 1, 15, 29 July, 12 August, 14, 23 October, 5, 10, 31 December. Type Multilateral deferred net settlement system. Participants 37 direct. Transaction types processed Low-value (up to THB 2 million) and, non-urgent THBdenominated electronic credit and debit payments. Operating hours 24 hours a day, Monday to Friday.

8 Payments are cleared and settled on a same-day or next-day basis. BPS calculates net clearing positions. Final settlement takes place via BAHTNET. Same-day settlement cut-off time = 12:00 ICT. Next-day settlement cut-off time = 12:30 ICT. ICAS System holidays BPS is closed on all Thai bank holidays. (Dates as above) Type Multilateral deferred net settlement system. Participants 36 direct. Transaction types processed Cheque payments which are truncated into electronic items before being processed. Operating hours 24 hours a day, Monday to Friday. Clearing cycle details (e.g. cut-off times) Payments are cleared and settled on a same-day or next-day basis. The BPS calculates net clearing positions. Same-day settlement cut-off time = 12:00 ICT. Next-day settlement cut-off time = 12:30 ICT. Final settlement takes place via BAHTNET. System holidays ICAS is closed on all Thai bank holidays. (Dates as above) Transaction volumes by instrument Transactions (millions) % change Value (THB billion) % change / /2016 Cheques ,895 59, Direct credit transfers ,309 17, Direct debit ,755 7, Online retail transfers ,184 3,

9 Debit cards Credit card ,510 1, Credit transfers Credit transfers are used by companies to pay salaries and suppliers and for treasury payments. High-value and urgent domestic THB-denominated credit transfers are settled in real time via BAHTNET. Low-value, non-urgent THB-denominated credit transfers are settled on a same-day basis via the BPS. Cross-border transfers can be made through BAHTNET via SWIFT. Direct debits Direct debits are used for regular payments, such as utility bills. High-value direct debits are settled via BAHTNET. Low-value direct debits are settled on a next-day basis via the BPS Debit Next Day service. Cheques The cheque is a common cashless payment instrument used by both consumers and small companies. All cheques are truncated into electronic items before being settled on a next-day basis via ICAS. Card payments Card payments are increasingly popular, especially for retail transactions. There were 53 million debit and 20.3 million credit cards in circulation in December There were also 8.7 million ATM cards. Visa and Mastercard-branded payment cards are the most widely issued. American Express and Diners Club credit cards are also available. Domestic card issuers include KTC Co., General Card Services Co., Cetelem, Tesco Card Services, Aeon Thana Sinsap, AIG card and Capital OK Co. Visa and MasterCard card payments are cleared and settled by their respective international card schemes. The Thai Payment Network (TPN), in partnership with UnionPay International and Bangkok Bank, operates a local-card network for processing electronic payments. ATM/POS There are approximately 113 ATMs per 100,000 adults in Thailand. There were 711,221 POS terminals in Thailand at the end of Most ATM payments are settled via the National ITMX, which connects to the international ASEANPay network. Internationally branded cards can be settled via their individual schemes.

10 Electronic wallet The dominant electronic wallet schemes in Thailand are low-value, stored value cards. There were 53 million stored value e-money cards in Thailand at the end of Payments are settled via individual schemes. The Mangmoom Card, the first integrated pre-paid card in Thailand, launched in June BNP Paribas capabilities BNP Paribas offers a variety of solutions specifically designed to meet customers' needs in Thailand. For example, the use of cash and cheques predominates in Thailand for corporations of all sizes as well as consumers. Consequently, BNP Paribas has invested significantly in supporting the domestic and international requirements of companies headquartered in, or operating in Thailand. In addition to its own services, BNP Paribas has established close, trusted relationships with local banks and vendors to provide access to comprehensive cash and cheque collection and deposit services, and support government-related and utility payments. Therefore, customers, or their clients/ customers can access partner banks' branch networks to deposit or make payments in cash or cheque. To enable efficient, automated reconciliation of collections, BNP Paribas also offers virtual account services to enable streamlined reconciliation of customer collections. Electronic banking Market overview Electronic banking services are available from most banks. Large companies are the predominant users. There is no national electronic banking standard in Thailand, so companies use banks proprietary services. An Online Retail Funds Transfer (ORFT) system enables interbank retail funds transfers to be performed through an interbank network via ATMs, internet, mobile or bank counters. Transaction and balance reporting and some transaction initiation services are available. Online and mobile banking services are provided by the country s leading banks. There are an estimated 20.5 million and 31.6 million internet and mobile banking agreements in Thailand respectively. The government s National e-payment Master Plan aims to transform Thailand in to a cashless society. BNP Paribas capabilities Both Connexis (online banking solution) and Connexis Connect (host-to-host connectivity solution) are available to customers in Thailand. Where there is no requirement for withholding tax or providing remittance information, SWIFT MT101 formats can be used; otherwise, XML formats are most appropriate. Liquidity management Domestic: notional pooling Domestic notional cash pooling in Thailand lacks legal certainty and legal advice should be sought.

11 Domestic: cash concentration Domestic cash concentration structures are widely available in Thailand. Exchange controls limit resident and non-resident bank accounts participating in the same cash concentration structure. Zero balancing is the most commonly used structure. Cross-border notional pooling Cross-border notional cash pools are not available in Thailand. Cross-border cash concentration Cross-border cash concentration structures are available to resident entities with a treasury centre licence from the BOT. Regulatory restrictions make cross-border cash concentration structures difficult to operate. BNP Paribas insights There are restrictions on intercompany lending and cash pooling (both physical and notional) in THB and foreign currency. These apply to both residents and non-residents. BNP Paribas provides domestic cash concentration, with MT101 arrangements with a leading local bank. Please contact your BNP Paribas Relationship Manager for more information. Short term investments Market overview Interest payable on credit balances Interest-bearing current accounts are not available. Demand deposits Demand deposits are not widely available. Time deposits Time deposits are available in THB or major foreign currencies for terms of three, six and 12 months. Treasury (government) bills The BOT auctions treasury bills on a weekly basis with maturities of one, three and six months. Government bonds are issued weekly with terms ranging from one month up to two years. Commercial paper Domestic commercial paper is available, although few domestic companies are able to issue unsecured paper. Most commercial paper is issued by financial institutions. When available, commercial paper is issued with terms up to 270 days, although terms between four and 12 weeks are most common.

12 Money market funds Money market funds are available. Repurchase agreements Bilateral repurchase agreements with maturities ranging from one week to six months are available. Banker's acceptances Banker's acceptances are not commonly used in Thailand. BNP Paribas insights There is no overnight deposits in Thailand; however, term deposits in both local and major foreign currencies are available. Please contact your BNP Paribas relationship manager for support and guidance on cash investment. BNP Paribas Trade Finance Capabilities Trade payments Documentary credits Documentary collections Supported by BNP Paribas Not required / permitted in THAILAND or not supported by BNP Paribas Guarantees Bank guarantees Standby letters of credit Supported by BNP Paribas Not required / permitted in THAILAND or not supported by BNP Paribas

13 Supply chain management Receivables Payables Inventory Supported by BNP Paribas Not required / permitted in THAILAND or not supported by BNP Paribas Trade channels Connexis Trade Connexis Supply Chain SWIFTNet Trade for Corporates Connexis Connect Supported by BNP Paribas Not required / permitted in THAILAND or not supported by BNP Paribas International trade General trade rules As a member of the Association of Southeast Asian Nations (ASEAN), Thailand has entered into the ASEAN Trade in Goods Agreement (ATIGA) between member states (Brunei Darussalam, Cambodia, Indonesia, Laos, Malaysia, Myanmar, Philippines, Singapore, Thailand, and Vietnam). Thailand is also a member of the ASEAN Free Trade Area (AFTA) and is committed to reducing and eliminating tariffs between members. As a member of the Asia-Pacific Economic Cooperation (APEC) forum, Thailand has agreed to liberalise trade and investment rules between members.

14 Trade agreements Thailand has signed free trade agreements (FTAs) with Bahrain, Australia, Chile, China, Peru and South Korea and economic partnership agreements with Japan and New Zealand. ASEAN has signed FTAs with Australia, China, Japan, India, New Zealand and South Korea. Thailand is in FTA negotiations with EFTA and the EU, India, Pakistan, Turkey and the USA. Imports / exports Imports Machinery and parts Intermediate goods and raw materials Chemicals Fuels Primary Import sources China (21.6%) Japan (15.8%) USA (6.2%) Malaysia (5.6%) Exports Electronics Computer parts Automobiles and parts Electrical appliances Machinery and equipment Export markets USA (11.4%) China (11.1%) Japan (9.6%) Hong Kong (5.3%) Australia (4.6%)Austra Consumer goods Wheat Cotton Dairy products Textiles and footwear Poultry Rice Malaysia (4.5%) Vietnam (4.4%) Import / export volumes Exports Imports , , , , ,106 - services USD m 58,642 55,347 61,759 67,685 75,651 - goods 218, , , , ,240 54,890 53,231 42,518 43,460 45, NA - goods USD m USD m - services USD m Current account as % GDP Source: IMF, International Financial Statistics, June Trade finance - imports Documentation The following documentation is required in order to import goods into Thailand: commercial invoice bill of lading Rubber

15 packing list customs declaration terminal handling receipts. Import licences Licences are not required for most imports. The Ministry of Commerce issues licences for controlled or restricted goods. The Food and Drug Administration issues licenses for certain food and pharmaceutical products. Import taxes and tariffs Tariffs are generally set at an ad valorem rate. In some instances, non-ad valorem specific rates, duty free rates or alternate duty rates, that are the higher of the ad valorem or non-ad valorem specific rate, are also sometimes placed on imports. Financing requirements None Risk mitigation Export-Import Bank of Thailand (EXIM Thailand), Thailand s national export credit agency, provides statesupported export credit insurance and financing. Export credit insurance and financing are also available privately from domestic and commercial banks. Prohibited imports Prohibited imports are published on a negative list. Thailand prohibits the import of certain items in order to protect fauna and flora, for health and safety or moral reasons, and/or for national security. Trade finance - exports Documentation The following documentation is required in order to export goods from Thailand: commercial invoice customs declaration terminal handling receipt bill of lading certificate of origin. Export licences Licences are required when exporting rubber rice, sugar, tinned tuna, coal, charcoal and textile products.

16 Export taxes and tariffs Tariffs are generally set at an ad valorem rate. In some instances, non-ad valorem specific rates, duty free rates or alternate duty rates are placed on exports. Financing requirements None Risk mitigation Export-Import Bank of Thailand (EXIM Thailand), Thailand s national export credit agency, provides statesupported export credit insurance and financing. Export credit insurance and financing are also available privately from domestic and commercial banks. Prohibited exports Prohibited exports are published on a negative list. Regulatory requirements Reporting regulations Foreign currency transactions with a value of USD 50,000 or above (or its equivalent) between resident accounts and accounts held by non-residents must be reported to the BOT on a daily basis. Reporting method Banks submit daily reports on their client's behalf via the BOT International Transactions Reporting System. Exchange controls Exchange controls are administered by the BOT. Liquidity provided by financial institutions to non residents without an underlying trade or investment is limited to THB 300 million. Borrowing from non residents is limited to THB 10 million. Proceeds from exports with a value above USD 50,000 by resident entities must be repatriated within 360 days of export and immediately after receipt of payment. A foreign exchange transaction form must be filed for proceeds of invisible exports or current transfers with a value above USD 50,000. Persons receiving foreign currencies are required to sell these currencies to an authorised bank or to deposit them in a foreign currency account with an authorised bank within 360 days of receipt. BOT approval is required for a resident to purchase securities and money market instruments abroad (institutional investors can purchase shares up to a value of USD 50 million without approval). Non-resident investors are not permitted to hold more than a 25% stake in domestic financial institutions, and no more than a 49% stake in other domestic companies. The BoT may give permission, in some cases, for greater foreign ownership and the MoF can authorise up to100% foreign ownership of some domestic companies. Non-residents require approval from the BOT, the Ministry of Finance and the Securities Exchange Commission to issue or sell securities and money market instruments in Thailand. The central banks of Thailand and Malaysia launched the operation of a local-currency settlement framework

17 for the settlement of MYR (Malaysian ringgit) and THB in The bilateral framework will make the process of obtaining THB in Malaysia and MYR in Thailand to settle import/export trade accounts much more efficient. The framework also covers THB and MYRdenominated financial services such as deposits and foreign-exchange hedging. Anti-money laundering / counter-terrorism financing Thailand has implemented anti-money laundering and counter-terrorist legislation, (the Anti-Money Laundering Act B.E (of 1999), as amended, most recently in 2015 by Anti-Money Laundering Act No 5 BE 2558; the Anti-Money Laundering Ministerial Regulations of 2000 and 2011; and the Counter-Terrorism Financing Act of 2013). The AMLO has also issued a series of related Ordinances. Thailand is a member of the Asia/Pacific Group on Money Laundering (APG). Thailand has a financial intelligence unit, the Anti-Money Laundering Office (AMLO), which is a member of the Egmont Group. The AMLO is an independent agency within the Department of Justice. Account opening procedures require formal identification of the account holder and beneficial owners. Customers making occasional cash transactions of THB 700,000 and above, or wire transfers or electronic transactions of THB 50,000 and above must be identified. All cash transactions equal to or above THB 2 million have to be recorded and reported automatically. For electronic transactions the threshold is THB 100,000. Financial institutions are required to conduct on-going customer due diligence. Financial institutions in the broadest sense must record and report large and suspicious transactions to the AMLO. Individuals travelling from Thailand to bordering countries require authorisation to carry THB exceeding THB 500,000 and, if travelling to other countries, require authorisation to carry THB 50,000. Individuals are allowed to carry any amount of foreign currency into or out of Thailand. Persons receiving foreign currencies are required to surrender these currencies to an authorised bank or to deposit them in a foreign currency account within seven days from receipt, unless they are foreigners temporarily staying in Thailand for not more than three months. The same rule applies to foreign embassies, and international organisations. Financial institutions must keep customer identification and specific transaction records for a period of ten years from the date the account was closed, or from the date the transaction occurred, whichever is longer. * Data as at June Taxation Resident / non-resident Resident/non-resident A limited company is tax resident if it is incorporated in Thailand. A branch of a foreign company or a partnership is considered tax resident if it is registered with the Ministry of Commerce (MOC) to conduct business in Thailand. For corporate income tax (CIT) purposes, a joint venture (JV) can be considered a taxable entity (separate from the JV partners) even if the JV is not incorporated or registered with the MOC but is registered with the Revenue Department. In these circumstances, the JV is liable for CIT (separately from the JV partners). A branch of a foreign company that (i) carries on a business in Thailand or (ii) has an employee, representative, or intermediary who engages in business activities for the foreign company in Thailand, is deemed to carry on a business in Thailand and is subject to CIT on Thailand-sourced income. Tax authority Thailand Revenue Department. (RD)

18 Tax year/filing The tax year is 12 months (a shorter year is allowed only in the year of incorporation, when there is a change of accounting period or in the year of dissolution). The CIT assessment is based on the company or branch's accounting year, and income tax is charged at the corporate tax rate for the period. A taxpayer must self-assess and make an advance corporate income tax payment for the first six months of the tax year. The half-year return must be filed within two months after the first six months of the tax year. The annual income tax return must be filed within 150 days from the company s year-end. Extensions are not available. Consolidated returns are not permitted for corporate income tax purposes; each company must file its own tax return. Financial instruments Thailand has no specific rules for the taxation of financial instruments. The tax treatment is based on general principles as articulated in the Thai Revenue Code, which are clarified in private tax rulings and court decisions. Interest and financing costs Whilst there are no specific rules for the taxation of interest and financing costs (e.g. thin capitalisation), they should in principle be determined by reference to market values. Foreign exchange The Thai Revenue Code (section 65 (5) and (8)) requires the following conversion of currencies, assets, or liabilities that are denominated in a foreign currency at the end of an accounting period: For companies or partnerships other than those specified in (b) below, the conversion of a currency or an asset into Thai currency is made at the average buying rate of commercial banks (as ascertained by the BOT), and the conversion of a liability is made at the average selling rate of commercial banks (as ascertained by the BOT); For commercial banks and other financial institutions designated by the Minister, the conversion of a currency, asset or liability into Thai currency is made at the average of the buying and selling rates of commercial banks (as ascertained by the BOT). The cost of goods denominated in a foreign currency is valued in THB using the market exchange rate on the date of acquisition. However, if there is an official exchange rate available (i.e. the rate declared by the BOT or commercial banks), that rate applies. Unrealised gains/losses from the conversion of foreign currencies are recognised in the taxable profits of Thai entities. Parties may prefer to denominate such amounts in Thai currency in order to avoid effects on taxable profits due to foreign exchange movements. Advance tax ruling availability Advance private rulings are available at the request of the taxpayer. The status of a private tax ruling in Thailand is not legally binding on the Thailand Revenue Department. There are several past tax rulings that are available for reference on the website of the Thai Revenue Department ( Advance pricing agreements (APAs) are available under the transfer pricing regime. Capital gains tax There is no separate capital gain tax: capital gains (sale proceeds minus original cost) derived by resident companies are treated as assessable income for CIT purposes. There are restrictions on the use of capital losses

19 to offset net taxable profits. A capital gain arising from or in Thailand to a non-resident company is subject to withholding tax at a rate of 15%, except where more beneficial treatment is provided for under a tax treaty. Withholding tax (subject to tax treaties) Payments to: Interest Dividends Royalties Other income Resident entities 1% or 10% 10% or exemption 3% N/A Non-resident entities 10 / 15% 10% 15% N/A 1. Interest paid to a non-resident company is subject to a 15% withholding tax unless the rate is reduced under a tax treaty. Interest paid on loans from a bank, financial institution or an insurance agency is subject to a 10% withholding tax rate if the lender is resident in a country that has concluded a tax treaty with Thailand, but an exemption applies if the interest is paid by a government or a Thai financial institution on loans granted under a law intended to promote agriculture, industry or commerce. A 1% advance withholding tax applies to interest payments made by a corporation to a corporation carrying on business in Thailand, or by a corporation to a financial institution for interest on debentures or bonds, except for interest on deposits or negotiable instruments paid between a bank or finance company. 2. Dividends paid to another Thai company are subject to a 10% withholding tax, or are exempt if certain conditions are satisfied. Dividends paid to a non-resident company are subject to a 10% withholding tax. The withholding tax rate on dividends paid to a non-resident may be reduced under a tax treaty. 3. Royalties paid to another Thai company are subject to a 3% advance withholding tax, which may be credited against the final corporate income tax due for the accounting period. Royalties paid to a non-resident are subject to a 15% final withholding tax, unless the rate is reduced under a tax treaty. Technical service fees paid to another Thai company are subject to a 3% advance withholding tax, which is used as a credit against the final corporate income tax due for the accounting period. Technical service fees treated as royalties and paid to a non-resident are subject to a 15% final withholding tax, unless the rate is reduced under a tax treaty. 4. A 10% branch remittance tax is imposed on after-tax profits paid or deemed paid to a head office. Tax treaties / tax information exchange agreements (TIEAs) Thailand has exchange of information relationships with 48 jurisdictions through 49 DTCs and no TIEAs. Thin capitalisation There are no specific tax rules in relation to thin capitalisation. There is no requirement governing the debt-to-equity ratio for a company registered in Thailand, unless it is required under specific circumstances (e.g. Thailand Board of Investment, terms with lender, foreign business licence, etc.).

20 Transfer pricing The 2002 transfer pricing guidance issued by the Thai Revenue Department (Departmental Instruction No. Paw. 113/2545) requires that related-party transactions are on arm s-length terms (broadly interpreted in line with the OECD Transfer Pricing Guidelines). Transfer pricing methods such as the comparable uncontrolled price, resale price-minus, cost-plus, or other internationally accepted methods are acceptable. Under the transfer pricing regime, taxpayers must declare in their annual corporate tax return whether revenue and expense transactions are based on market prices, and the tax authorities may adjust income to reflect a market price. Advance pricing agreements may be obtained and, while transfer pricing documentation is not formally required to be maintained, there is an assumption (based on filing requirements and directives to revenue officers) that documentation should be available by the corporate income tax return filing date. A taxpayer may initiate an adjustment (up or down) if there is adequate documentation to substantiate the adjustment. A new transfer pricing regulation is expected to come into force in Stamp duty Normally, the transfer of shares, debentures, bonds and certificates of indebtedness is subject to stamp duty at a rate of 0.1% on the greater of the value of the paid-up registered shares or the value as defined in the instrument, unless an exemption is applicable, and 0.05% (capped at THB 10,000) on loan agreements. The transferor is liable to pay the stamp duty. Cash pooling There are no specific tax rules for cash pooling arrangements. Financial transactions / banking services tax Apart from VAT or SBT, no specific financial transactions and/or service taxes apply to services, loans, money transfers, and letters of credit. All tax information supplied by Deloitte Touche Tohmatsu and Deloitte Highlight 2018 ( This content can be accessed by registered users only. Please register or log in to BNP Paribas Atlas. Register Log in Market data updated as of 01/08/2017

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