With a significant occurrence of cross border transactions, the importance of transfer pricing rule has captured the tax authority’s attention. In Indonesia, domestic transactions between associate enterprises are subject to transfer pricing rule as well. In order to ensure that the enterprises carry out their related party transactions in accordance to the Indonesian tax regulations and transfer pricing guidelines, the Indonesian tax authority requires transfer pricing documentation for each intercompany transaction.
It is increasingly important for enterprises to pay particular attention in their corporate behavior and how enterprises determine the pricing of their products or services to their associates in accordance with the arm’s length principle.
PB Taxand has years of experiences in handling tax audit, tax objection and litigation including transfer pricing. As transfer pricing issues get more complex, PB Taxand created a special Transfer Pricing Team which works together with our corporate tax division in handling transfer pricing cases.
PB Taxand’s Transfer Pricing Team is supported by the network of Taxand experts located in more than 50 countries, as well as global support resources which include transfer pricing databases, trainings and all other resources.
The Transfer Pricing related services provided by PB Taxand are as follows:
* Group Structuring
* Transfer Pricing Documentation
* Advance Pricing Agreement
* Tax audit, Tax Objection, and Appeal
Group Structuring
We provide strategic advices on the group structure as well as assistance in conducting the business structuring review, especially on the related party transactions, in accordance with the Indonesian tax regulations and Transfer Pricing guidelines.
Transfer Pricing Documentation
We assist in the preparation of integrated Transfer Pricing Documentation to establish compliance with the requirements of the Indonesian tax authority and in accordance with the OECD Transfer Pricing Guidelines to create a credible Transfer Pricing Documentation.
Advance Pricing Agreement
We assist in the process of unilateral and bilateral Advance Pricing Agreements with tax authorities, starting from the preparation of supporting documents to obtaining approval from tax authorities.
Tax audit, Tax Objection, and Appeal
We assist in explaining the Transfer Pricing Documentation for the purpose of tax audits, objections, and appeals.
