Muhamad Fajar PutrantoSenior Advisor

Fajar has more than 28 years of experience in Taxation, including 16 years of experience at the DGT and 12 years as a tax consultant. While working at DGT, he was appointed as one of the special team to review and provide input to the tax auditor and Objection Reviewer regarding international taxation issues and transfer pricing at Large Taxpayers Office 2 (LTO2), DGT. With Fajar’s involvement with the special team, he has gained an in-depth grasp of the regulations related to transfer pricing, demonstrated by his knowledge of PMK 172/2023, the updated regulation of PMK 213/2016 as well as PMK 22/2020.

Fajar has practical expertise in representing clients before the DGT in tax advisory, MAP/APA, audit, and objection, as well as handling litigation of some of the largest and most complex cases in the appeal phase. During his professionalism as a tax consultant at TaxPrime, he has consistently been successful in defending clients’ positions involving a wide variety of domestic and international tax issues, including transfer pricing, particularly related to cross-border sales of commodities, license of intangibles, and intra-group service. Most of these issues have been settled without resorting to litigation, achieved through discussions and presenting the case to tax authorities. Furthermore, Fajar’s distinctive approach involves a deep understanding of the client’s business processes, equipping him with the expertise to provide advisory on business, customs, and Environmental, Social, and Governance (ESG) matters.

Highlighted Matters

Fajar has successfully assisted clients in numerous cases, some of them are:

1. 1. 1. 1. Planned, advised and implemented the most appropriate tax facilities for the leading copper smelting and refining companies in Indonesia. The appropriate facilities would affect the advancement in production and financial, and also impact the improved compliance level, so that future and continuous tax disputes can be well managed and avoided.
         2. Planned, advised, and executed the strategies to resolve the continuous and significant disputes experienced by the mining company with the world largest gold deposit. The disputes arose from the treatment of significant costs, whether they shall be expensed or capitalized for tax purpose. One of the resolution strategies was to prepare a comprehensive study concerning the activities or events raising the costs covering whole treatment views including commercial, industry, mining engineering, legal, accounting, and tax. Next strategy was to assist the company in presenting the comprehensive study and resolving the continuous disputes with the Indonesian Tax Authority.
         3. Successfully challenged and resolved tax audit assessments in the objection stage, the dispute resolution forum before appeal to the tax court, that the leading copper smelting and refining company in Indonesia dealt with. The adjustments resolved comprised of the complex financial transaction and biggest adjustments continuously imposed and disputed during tax audit by DGT and the client i.e. hedge transactions.
         4. Represented the second biggest mining contractor in Indonesia during tax audits for several fiscal years and successfully resolved disputes arising from the most significant and complex issues in repair and maintenance costs, whereas most competitors in the industry already suffered and failed to resolve the issues during tax audits.
         5. Successfully assisted and represented the leading copper smelter company in Indonesia in resolving transfer pricing adjustments imposed on purchase of metals from the biggest copper and gold miner where such adjustments were eventually dropped during objection stage.