KTNP Transfer Pricing Transfer Pricing Indonesia | Best Transfer Pricing Web

LoginRegister
Home » Services » Displaying items by tag: Business
Bahasa IndonesiaEnglish (United Kingdom)
A+ R A-
Displaying items by tag: Business
Friday, 09 November 2012 00:20

Our Service

These below are our kind of services in regard transfer pricing:

- Preparing TP study and TP Documentation
- Revise or amend the TP Doc been prepared from Europe and/or OECD model to Indonesian Model
- Objection and appeal special for transfer pricing cases
- Research services to seek the comparative data for certain business like manufacturing contract, Patent, franchise, etc (The interval will be used by either small and big sampling)
- General consultation for transfer pricing
- Public and in house training for Indonesian transfer pricing model
- General Tax Services ( Tax audit, Tax objection and Tax appeal at Tax Court)
- Tax due diligent

- REGISTERED PUBLIC ACCOUNTANT

a. Prepare CPA Audit Report
b. Accounting Services
c. Compilation Services
d. Financial Review

Contact for audit : Natan 0822 98304243
Anton 0813 50414342
Published in General Data
Friday, 09 November 2012 02:36

Inadequate of TP Doc

Inadequate of TP Doc

Based on Tax Director Circulation letter number PER-32/PJ./2011 concerning about Arm’s Length Principle the minimum analysis must be considered to be performed in preparing TP Doc are as follows:


Functional analysis (FAR) consist of:

1. Function Performed

2. Asset employee

3. Risk assumed

 

Economic Analysis consist of:

1. Geographic location

2. Market Size

3. Competition aspect

4. Availability of services or product replacement

5. Demand and supply

6. Customer purchasing of power

7. Government rule and policy involvement in market

8. Production cost

9. Date and time of transaction


Company must analyze all aspects comparable items as mentioned above as ruled to fulfill the minimum requirement. If one or more comparable items are not available, our professional’s judgment classified that document as inadequate TP Doc. It could create a big issue between Indonesia tax authority and tax payer.


Transfer Pricing Method

Indonesia Tax authority accepted these following methods:

  1. Comparable Uncontrolled Price / CUP (Metode perbandingan harga antara pihak yang tidak mempunyai hubungan istimewa
  2. Reseale Price Method / RPM (Metode Harga Penjualan Kembali)
  3. Cost Plus Method / CPM (Metode Biaya-Plus)
  4. Profit Split Method / PSM (Metode Pembagian Laba)
  5. Transactional Net Margin Method / TNMM (Metode Laba Bersih Transaksional)
Published in General Data
Friday, 09 November 2012 04:27

Transfer Pricing

Transfer Pricing and Fundamental Price

The fundamental principle is that the transfer price should be similar to the price that would be charged if the product were sold to out side customers or purchased from outside vendors. Transfer pricing, for tax purposes, is the pricing of intercompany transactions that take place between affiliated businesses.

A deal between two interrelated or enterprise associates parties. That is behavior as if they were not related, so that there is no query of a disagreement of attention. In simple way we can describe this as “a deal between two unconnected or associate parties”. The concept of an arm's length deal is to make sure that both associates in the transaction are behave in their self attention and are not issue to any force or pressure from the other associate.

International transactions dealt between two or more Associated Group Enterprises or entities, are called Intercompany Transfer Pricing.

Transfer Pricing and Audit risk

Tax payer must disclose of related-party transactions in the tax return. Domestic and international related-party transactions are required to be disclosed. The information that must be disclosed includes the type of transaction, the value of the transaction, the transfer price and the method used to determine the transfer price.
In practice, taxpayers that exhibit the following characteristics are more at risk of being subject to a transfer pricing audit:

•    A large number of related-party transactions
•    Losses situation and process the tax claim
•    An increase in gross revenue or receipts but no change in net profit
•    Associated parties in tax havens
•    Lower net profit in comparison to the industry average or other similar enterprises.
Published in General Data

Images Photo Gallery

Tax Audit on Transfer Pricing


Indonesia Tax Director has released the circulation letter number SE-07/PJ/2012 about the tax audit strategic. Based on that circulation letter, one of the tax audit object is the entities with the transfer pricing exposure. read more...

Joomla Templates and Joomla Extensions by JoomlaVision.Com

LiveChat With Us

Office Address

Level 30th, South Tower
Sampoerna Strategic Square
Jl Jenderal Sudirman Kav. 45–46
Jakarta 12930, Indonesia
Phone :  (021) 2993 0808
Fax      :  (021) 2993 0888

Login

login