As explained in my earlier post, BEPS (Base erosion and profit shifting) refers to tax avoidance strategies that exploit gaps and mismatches in tax rules to artificially shift profits to low or no-tax locations.  Although Thailand will be participating in BEPS action plan, the Thai government will not be following the time-line of the OECD/G20 countries.  Here are some challenges that, I believe, the Thai government is facing:  One, we have seen how the government has been trying to attract or retain investors.  Why not? According to reports, the average growth of Thailand has slowed to 3.5% over the last 10 years.  Accordingly, designing a tax policy that is pro business and at the same time would protect its tax base would definitely be a challenge. Moreover, building capacity and resources has always been an issue.  For example, the mandatory transfer pricing (TP) documentation would require TP capability not only at the level of the Large Taxpayer's Office (LTO) but also at the local revenue offices.  Thus, the need to defer the issuance of the long-awaited transfer pricing regulation, among other reasons.  Moreover, Thailand needs a more effective exchange of information, which currently is being done on a request basis under the relevant double tax agreement.