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Transfer pricing matters have gained significant attention from tax authorities due to the potential for transferring assets and income across jurisdictions with favorable tax rates. Therefore InCorp Indonesia’s transfer pricing services provide advisory in guiding businesses on transfer pricing matters.

Tax authorities have implemented comprehensive regulations and intricate documentation requirements in Indonesia to address this issue. Nevertheless, our experts in transfer pricing advisory will cater to your specific needs.

Our Transfer Pricing advisory services are designed to cater to your specific business needs while ensuring compliance with Indonesian legal requirements and international best practices. Our team will provide you with the following:

Transfer Pricing Advisory

InCorp Indonesia provides comprehensive transfer pricing compliance services to ensure businesses meet local and international regulatory requirements. In Indonesia, transfer pricing plays a crucial role in determining the pricing of transactions between related parties.

As part of the compliance process, companies must submit a summary in a prescribed format along with their Annual Corporate Income Tax Return. The summary should include the following information:

  • Determine an arm’s length price range for related party transactions.
  • Reviewing the value chain for risk identification and improvement opportunities.
  • Reviewing intercompany agreements for transfer pricing compliance.
  • Conduct royalty benchmarking for IP transactions.
  • Managing cross-charge documentation and analysis.

It is important to note that this information should be submitted in addition to the Special Attachment Forms (Forms 3A/3A-1 and Forms 3B/3B-1) filed along with the Annual Corporate Income Tax Return.

Transfer Pricing Compliance

InCorp Indonesia provides comprehensive transfer pricing compliance services to ensure businesses meet local and international regulatory requirements. In Indonesia, transfer pricing plays a crucial role in determining the pricing of transactions between related parties.

As part of the compliance process, companies must submit a summary in a prescribed format along with their Annual Corporate Income Tax Return. The summary should include the following information:

  • Verification of whether the Master File and Local File contain the necessary information as per the regulations.
  • Declaration of the availability date of the Master File and Local File, as stated in the statement letter.

It is important to note that this information should be submitted in addition to the Special Attachment Forms (Forms 3A/3A-1 and Forms 3B/3B-1) filed along with the Annual Corporate Income Tax Return.

Note | PMK-213 does not replace the existing Transfer Pricing regulation issued by the Directorate General of Taxation under Regulation No. PER-43/PJ/2010 (amended by Regulation No. PER-32/PJ/2011). Therefore, businesses may need to comply with the documentation requirements of both Regulation No. PER-32/PJ/2011 and PMK-213 in parallel.

Transfer Pricing Documentation

Indonesia implements BEPS Action Plan 13 (PMK-213), requiring TP Doc for all transactions. Taxpayers must maintain a Master File, Local File, and CbCR in Bahasa Indonesia. A statement letter declaring the availability of Transfer Pricing Reports should accompany the files. Non-compliance can lead to audits and penalties.

With services offered by InCorp Indonesia, we ensure that businesses accurately prepare the necessary documentation and comply with the applicable regulations, minimizing the risk of penalties and disputes related to transfer pricing activities.

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