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Displaying items by tag: tax
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 06:01

Warning: GAP Regulation!

We found that some TP docs for Indonesian entities have not been made by using Indonesian TP Doc model. Many transfer pricing expert have prepared the TP study and TP doc applied the OECD guidelines for Indonesia tax payer. This practice happened because the lack of knowledge of transfer pricing expert in Indonesia. This situation forced many tax and accounting firms engaged the international practitioners who mastering the Europe model to do the TP study for Indonesian tax payer.

To anticipate tax risk issue in the future, Indonesian company should ensure that the TP Doc will be prepared by Indonesian TP doc Model as per regulation number PER-32/PJ./2011. To remodel (to revise) company TP doc as per Indonesian Model, you can contact us for further information.

Published in General Data

Indonesia Tax Model

Transfer pricing Study is a study which can be documented considering the international transactions between the two or more Associated Enterprises. read more...

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.

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