Transfer Pricing Documentation

Indonesia has adopted the OECD BEPS Action 13 regarding Transfer Pricing Documentation and Country-by-Country Reporting in PMK 213/PMK.04/2016 (“MoFR”). The MoFR has fundamentally renewed the concept and the approach of the previous regulation, e.g., the three-tiered Transfer Pricing Documents: Local File, Master File and Country-by-Country Report (CbCR), minimum information required,  and the deadline for the preparation. Further, a significant change is related to the ex-ante analysis, expecting taxpayers to perform the arm’s length analysis based on the information available at the time of the transaction. Therefore, the documents are expected to demonstrate the arm’s length nature of the pricing policies set by taxpayers for its related parties transactions. The approach differs from the ex-post which is widely adopted by jurisdictions.

Our team will help you to prepare the transfer pricing document as required by the Indonesian regulations i.e. the application of ex-ante analysis. Our unique approach in assessing the arm’s length nature of the transactions will increase the level of compliance and, thus, mitigate unnecessary disputes.

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