On 18 November 2018, amendment of Revenue Code was declared. The main points are followings:
1．In the case that a company or a juristic partnership is related in finance or commerce and there deemed to have a profit transfer each other , the assessment officer has the power to adjust the income and expenses of such company or juristic partnership.
2．In the case that a company or a juristic partnership is related in finance or commerce each other , regardless of whether the relationship exists throughout the accounting period or inter-transaction between accounting periods or not, it should prepare a report of the total value of transactions each accounting period in the form prescribed by the Director-General and submit to the assessment officier together with tax return within 150days (Section 69).
3．The relationship under 1 and 2 means following 3 cases:
（1）A juristic person holds shares of in another juristic person, directly or indirectly not less than 50% of the total capital.
（2）Shareholders holding shares of one juristic person directly or indirectly, at least 50% of the total capital holds shares of another juristic person directly or indirectly, at least 50% of the total capital.
（3）Juristic person with relationship between capital, management or control In a manner that a juristic person may not operate independently from another juristic person as prescribed by the Ministerial Regulations
4. Within 5 years from the date of submitting a report under paragraph 2, with the approval by the Director General, the assesment officer may send a notification to the company or juristic partnership to submit documents or evidence showing the information necessary for the analysis of the requirements and and the person received the notification must submit the documents within 60 days from the date of receipt of the notification (In the case of necessity,the Director-General may allow the extension of such schedule, but must not exceed 120 days from the date of receipt of the notification, only in the case of receiving the first notification).
5．This act shall not apply to a company or a juristic partnership that has income of the accounting period not exceeding the number or any other characteristics as prescribed in the Ministerial Regulations which the amount of such income must not be less than Baht 200 million.
6．This act shall apply to income of a company or a juristic partnership in which the accounting period begins on or after 1 January 2019 onwards.
7．Whoever fails to submits report ,documents or evidence under 4.or shows incomplete, incorrect and unreaonable information shall be liable to a fine not exceeding Baht 200,000.
<original Thai version>
->to following website of Revenue Department
http://www.rd.go.th/publish/fileadmin/user_upload/kormor/newlaw/prb47.pdf