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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


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 04:17

Indonesian Tax Authority Right

Indonesian Tax Authority Right

Indonesian tax authority has right to asses the tax amount must be paid by tax payer if company treat the uncontrolled transaction did not applied the fair market value as ruled by Indonesian Director Rule number: PER-32/PJ./2011 concerning about Arm’s Length Principle. This following action can be performed by Indonesian Tax Authority in regard of transfer pricing cases:

  1. Special tax audit on transfer pricing
  2. Adjustment
  3. Tax investigation

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.

Tax Audit Scope

As stipulated on Indonesia Tax Director circulation letter number SE-85/PJ/2012 about tax audit policy the tax audit scope are as follows:

  1. The related tax and accounting period (one year period)
  2. Several periods for all taxes or part of taxes (previous year)


Audit Time on Transfer Pricing

Total audit time will be spent on special audit for transfer pricing up to 24 months.

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

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Phone :  (021) 2993 0808
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