• Santana Saksudhayakom is a transfer pricing specialist at PKF Thailand. She joins us since December 2023. Santana is a highly recognizable and outstanding experienced and expertise specialist in a transfer pricing in the past from both the Revenue Department and Big4 company. Her transfer pricing experience and expertise is over 45 years.
• Before joining PKF Thailand, she was the head of transfer pricing audit and advanced pricing arrangement (“APA”) working team and the head of the Large Taxpayer Supervision Team (“LTO”) at the Revenue Department. She deliciated her working life for the tax authority over 35 years and, thereafter, worked as the transfer pricing specialist at one of the Big4firms for over 6 years.
• Her outstanding expertise in this area includes advising and supervising on inter-company transactions of the latest-scale multi-national companies (“MNE”) on pricing policy and benchmarking study as well as reviewing on and participating in Advanced Pricing Agreement (“APA”), including involving in the process of the relevant Mutual Agreement Procedure (“MAP”) and advising other transfer pricing matters.
• In addition to the above, she was the committee in drafting and finalizing the transfer pricing rules and regulations, including Departmental Instrument No. Paw 113 and APA guidelines and internal guidances during her time at the Revenue Department.
• She has handled and assisted a taxpayer and a company on transfer pricing disputes and audit. She has negotiated with the tax comptrollers for a taxpayer and a company as well as provided a transfer pricing advisory services, including commenting on the local file preparation, and the benchmarking study for both Thai and non-Thai multinational companies in various field of businesses and industries on the related party transactions for both domestically and internationally in various field of business and industries.
• She holds a Certified Public Accountant (CPA) and is the Tax Accounting Committee (2023-2026) of the Federation of Accounting Profession.