Practice area

World TP Reviews

Transfer pricing
Baker McKenzie

The transfer pricing practice at international firm Baker McKenzie benefits from the wide-ranging network the team is able to offer. This was exemplified recently in its work involving a Denmark-headquartered company.


The Deloitte Thailand transfer pricing team has 22 members, with Stuart Simons and Kancharat Thaidamri serving as the two partners. It has been a crucial player engaging with the development of transfer pricing policy and practice of the Revenue Department of Thailand (RDT) since the release of the first transfer pricing guidance in 2001 and has offered training to the RDT officers. It has also helped to shape the rules and practices for bilateral APAs, by providing help in the first new APAs agreed by the Thai tax authority (with Japan). The team is currently preparing transfer pricing documentation services as the imminent release of the transfer pricing documentation brings a high demand for that.

The team has a strong ability to support Thailand’s larger multinationals, addressing their global documentation requirements, because of the strength of the Deloitte network. In 2017, this included helping a client with its global transfer pricing documentation requirements.


The KPMG transfer pricing team has almost 30 professionals and staff. It is in a leading position as part of the discussions to help with the design of the new transfer pricing regulation, which is expected to become effective in 2018. The transfer pricing team is also supported by global transfer pricing professionals from KPMG International member firms, which helps the KPMG Thailand transfer pricing team establish a strong ability to understand difference national transfer pricing regulations and offer integrated global transfer pricing advisory and compliance services. The team mainly assisted clients in the petroleum, automotive, consumer products, electronics and agriculture and food industries in 2017.

Abhisit Pinmaneekul, one partner at KPMG Thailand, assisted a Thai-listed company reviewing a business model from a transfer pricing perspective and making a feasibility study for an eventual project valued at around $5 billion. The transfer pricing team engaged with the clients in conducting a review of the business model, cost structure and pricing strategy for its regional headquarters’ business activities and trading business activities. 

KPMG has brought new valuable resources to the transfer pricing team, including the former head of the transfer pricing audit team and APAs committee at the Revenue Department of Thailand.

Tilleke & Gibbins

One recent matter that the team at Tilleke &Gibbins advised on saw it working with Skidmore Owings & Merrill, an international architecture firm, in connection with the development of a major project in Bangkok.