ニューズレター
TMI Eyes No. 4: Year-End Profit Adjustment and Tax Implications
2023.05.01
It is relatively commonplace for group companies to conduct transfer pricing studies, and in many cases, apply resale minus, cost-plus, or transactional net margin method (“TNMM”) to their financials, which frequently leads to year-end profit adjustments. At a glance, year-end profit adjustments seem to be in line with transfer pricing norms; however, it should be noted that such adjustments often result in non-compliance with customs valuations and lead to corporate income tax and VAT implications. In this article, TMI will discuss the tax implications of these year-end profit adjustments and how companies can prepare in the event of an audit from the Thai Revenue Department and Customs Department.