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TRANSFER PRICING RISK WITHIN AUTOMOTIVE INDUSTRY IN THAILAND |
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| รหัสดีโอไอ | |
| Creator | Paranyu Vitanakorn, Sillapaporn Srijunpetch |
| Title | TRANSFER PRICING RISK WITHIN AUTOMOTIVE INDUSTRY IN THAILAND |
| Contributor | - |
| Publisher | TuEngr Group |
| Publication Year | 2563 |
| Journal Title | International Transaction Journal of Engineering, Management, & Applied Sciences & Technologies |
| Journal Vol. | 11 |
| Journal No. | 11 |
| Page no. | 11A11T: 1-11 |
| Keyword | Tax risk assessment, COSO ERM 2017, OECD, BEPS Actions, Transfer pricing risk factors, Transfer pricing risk mitigation, Intellectual Property (IP), Advance Pricing Agreement (APA). |
| URL Website | http://TuEngr.com/Vol11_11.html |
| Website title | ITJEMAST V11(11) 2020 @ TuEngr.com |
| ISSN | 2228-9860 |
| Abstract | The purpose of this study is to assess transfer pricing risk within the automotive industry in Thailand based on COSO ERM 2017; identifying transfer pricing risk, prioritizing risk by rating its severity, and developing appropriate risk response to mitigate risk. The findings and results of this study show that there are five potential key transfer pricing risks sorted by the severity of risk in descending order from intellectual property, profit allocation in accordance with the risk-bearing function and capital, high-risk transaction related to service, arm's length price calculation, and pricing policy and interest. The most efficient and sustainable method to mitigate risk is to understand the business so that the most suitable pricing policy can be selected and embedded into the business plan. In addition, all firms should anticipate auditing from the Thai Revenue Department by regularly reviewing the pricing policy. Another effective risk response for the companies with changes in functions or business structure is to agree on the profit range and pricing policy in advance with the Thai Revenue Department. It is called the Advance Pricing Agreement. |
