Is it mandatory to report related-party transactions in Thailand? This article clarifies the complia

Emory Views: 10 2026-05-06 12:29:27 Comments: 0

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What is a Disclosure Form?

Disclosure Form

It is based on Section 71 Bis of the Thai Revenue Code, which requires companies or juristic entities with related-party relationships to prepare and submit an annual report. This form must be submitted together with the corporate income tax return (PND.50) to disclose related-party transactions to the Revenue Department Thailand.

It must also be:
Submitted together with the corporate income tax return (PND.50)

Its core purpose is to disclose related-party relationships and transactions to the tax authorities for the assessment of the reasonableness of related-party transactions.

Which companies are required to file?

The following two conditions must both be met:

Existence of a related-party relationship
Including but not limited to:
Shareholding of at least 50% (directly or indirectly)
Multiple companies controlled by the same shareholder holding at least 50%
Dependency in terms of capital, management, or control
(i.e. the companies are unable to operate independently)
Annual revenue exceeding THB 200,000,000
Annual revenue of at least THB 200 million
(Meeting both conditions constitutes a mandatory filing obligation)

Filing timeline+Foling method

The Disclosure Form must be submitted together with the PND.50:

Standard deadline: within 150 days from the end of the accounting period
e-Filing submission: extended to within 158 days
(an additional 8 days is granted for electronic filing)

Submitted online through the Revenue Department’s e-Filing system

If online submission is not possible:

A hard copy submission may be made with an explanation provided for the reason.

What information must be disclosed?

主要包括：

关联公司名单（境内及境外）
各类关联交易金额（年度汇总）
集团结构及是否存在合并报表
是否发生业务重组或无形资产转移

（相关信息将作为税局判断企业关联交易的重要依据）

不申报的风险

According to Section 35 Ter of the Thai Revenue Code, if any of the following situations occur:
Failure to file or late filing
Incomplete or inaccurate information provided

👉 A penalty of up to THB 200,000 may be imposed

Practical enforcement standards:
Delay of no more than 7 days: THB 50,000
Delay exceeding 7 days: THB 100,000
If identified by the Revenue Department: THB 200,000

For companies operating in Thailand, especially those with intra-group transactions, the Disclosure Form is not only a filing obligation, but also an important tool used by the tax authorities to identify related-party transaction risks.

Companies are advised to prepare in advance:
Related company structures / transaction data / group information

To ensure filing completeness and avoid penalties or potential tax risks.

Summary:

TMA recommendation:

The Disclosure Form is an important part of corporate tax compliance:
✔ Filing is mandatory if the conditions are met
✔ It must be submitted together with the corporate income tax return
✔ It serves as a key basis for the tax authorities to assess related-party transactions

Companies should incorporate it into their regular tax and financial management system, rather than treating it as a temporary task.

END

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