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Mar. 2--Typically, Thai subsidiaries of multinational companies are financed through a combination of equity and debt. That debt may, in many cases, be sourced from a related foreign company. It is also not uncommon for Thai companies with excess funds to make loans to group companies within or outside Thailand to finance their working capital needs.
The Revenue Department's transfer pricing guidelines require that the interest rate on a loan between related parties be comparable to the going market rate unless they can provide some justification that is acceptable to the tax authorities. Determining the most appropriate interest rate in accordance with the department's guidelines may, however, require complex analysis.
Generally, the department's transfer pricing regulations rely on the internationally accepted "arm's length" principle. Under this principle, the interest rate charged on a loan between related companies ...