Transfer Pricing Documentation

Since December 2016, DGT has adopted the OECD BEPS Action 13 regarding Transfer Pricing Documentation and Country-by-Country Reporting in the PMK 213/PMK.04/2016 (“MoF”). The MoF has fundamentally renewed the concept and the approach of the previous regulation, e.g. the Documents need to be prepared, the ex-ante approach, the minimum information needed to be presented on the Documents, languages used, and the deadline of the preparation that need to be carefully addressed.

We would assist and help our client in the preparation of the Documents as required by the Indonesian regulations. In addition, we have developed a unique approach to examine the related party transactions therefore in case of dispute, the risk will be mitigated.

 

Translate and Review Master File

As the requirement of the Master File varies depending on domestic tax laws, such as the minimum information and language used, therefore it is likely that the Master File prepared by foreign entity may not be suitable to be adopted by an Indonesian entity. In such a case, to avoid the rejection of the documentation and further scrutiny by DGT, it is beneficial for the company to provide the Master File which complies with the Indonesian tax Regulation.

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