The Thai Revenue Department has published Ministerial Regulation No. 369 of 6 November 2020. The relatively brief regulation sets basic rules to be followed by the tax authority when evaluating whether transactions between related parties have not been conducted at arm's length, leading to profit shifting. This includes cases where:
- The price and terms for the sale goods or services is different than what would be agreed to by independent parties for similar goods or services in similar cir…