Transfer Pricing
With long experience in transfer pricing, DRKI’s team of economists, accountants, and lawyers offers a full range of transfer pricing services to clients.  Three key transfer pricing services that are usually required by the clients include:










Transfer pricing documentation service

DRKI assists multinational enterprises in preparation and documentation of transfer pricing reports that analyze the arm’s length nature of their intercompany prices. We can assist our clients in preparing the local files that comply with Thai transfer pricing regulations.  We can also help our clients develop the transfer pricing master files that satisfy the documentation requirements under Base Erosion and Profit Shifting (“BEPS”) Action 13.

Price-setting service

DRKI assists clients in developing inter-company transaction pricing strategies, and determining effective transfer prices that are consistent with the arm’s length principle through transfer pricing benchmarking analyses.

Transfer pricing audit defense service

DRKI supports customers’ tax position by providing facts and supporting documents and mitigating or terminating risk of transfer pricing allegation and audit.

Transfer pricing strategic planning

DRKI advises and assists clients in realigning ineffective business model by developing inter-company transaction structure and selecting appropriate pricing strategies that optimizes shareholders’ value while setting prices that are consistent with the arm’s length principle. 



















Advance Pricing Agreements

DRKI, together with our international alliance, assists our clients to prepare, apply for and negotiate the Advance Pricing Agreement (“APA”) with tax authorities so as to avoid future transfer pricing disputes by entering into a prospective agreement, generally covering at least five tax years.
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