Revenue Departmental Instruction No. Paw. 113/2545 on Corporate Income Tax - Determination of Transfer Price based on the Market Price

International business transactions have increased dramatically over the years. Investment has increasingly expanded at an unprecedented rate in many countries. These international business activities have led to the formation of a group of companies with mutual interests which is known as “multinational enterprise” (MNE). Companies within the MNE may trade goods or services with one another by means of “Transfer Pricing”. The Revenue Department is aware of practical problems in calculating the market price. Therefore, the booklet “Determination of Market Price for Multinational Enterprises” is accordingly written to provide businesses with guidelines in determining acceptable market prices in accordance with international principles.