Indonesia Transfer Pricing Policy

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TP-Q-10
Why kinds of scenarios will be adopted TP policy? What is the relevance between DTA and TP policy?

TP-A-10
When Indonesia Tax entity would like to pay out whatever business profits, Royalty, Technical Services fees, Interests, trading amount etc.,
it will adopt DTA tax rate. Its judge criteria, please see the Indonesia Treaty Page.
But if want to verify the above-mentioned amount if reasonable, will adopt Indonesia TP Policy.

TP-Q-20:
印尼在甚麼情況下, WFOE 外商投資企業不需要同時處理TP 申報和文件申報?
What are the scenarios in Indonesia, that a Wholly Foreign-Owned Entity (WFOE) is exempted from compliance of Transfer Pricing (TP) declaration and TP documentation?

TP-A-20:
You are exempted from TP declaration and TP documentation if you do not have any related party transaction.

TP-Q-30:
印尼在甚麼情況下, WFOE 外商投資企業需要向該國的稅務局發送TP 申報? 甚麼是申報單名稱?
What are the scenarios in Indonesia, that a Wholly Foreign-Owned Entity (WFOE) is required to submit a TP declaration to the country’s tax bureau? What is the name of the TP declaration form?

TP-A-30:
One or more related parties (domestic or International) transactions.

1. Summary (ikhtisar) form
2. Forms 3A/ 3A-1/ 3A-2 (for books of accounts maintain in Rupiah) or Forms 3B/ 3B-1 / 3B-2 (for books of accounts maintain in USD).
3. CbCR Notification form

TP-Q-40:
在印尼甚麼情況下, WFOE 外商投資企業需要向該國稅務局發送TP 申請和文件? 甚麼 declaration 表單名和文檔名?
What are the scenarios in Indonesia, that a Wholly Foreign-Owned Entity (WFOE) is required to submit TP declaration and TP documentation to the country’s tax bureau? What is the name of the TP declaration form and TP documentation form?

TP-A-40:
Consolidated Group Revenue of UPC’s current fiscal year 11 trillion Rupiah (757 million USD).

TP Declaration form

1. Summary (ikhtisar) form
2. Forms 3A/ 3A-1/ 3A-2 (for books of accounts maintain in Rupiah) or Forms 3B/ 3B-1 / 3B-2 (for books of accounts maintain in USD).
3. CbCR Notification form

TP Documentation form

1. Local File
2. Master File
3. CbC Report

Indonesia TRANSFER PRICING for professionals

Overview

PMK-213/PMK.03/2016 (PMK-213) regulates the documents or information relating to related party transactions to be retained.
Following to that, DGT Regulation No. 29/PJ/2017 (PER-29) has issued a regulation on Country-by-Country Reports.
In general, transfer pricing rules in Indonesia are aligned with the OECD Transfer Pricing Guidelines.
Every related party transaction, both local and international, are required to provide Transfer Pricing (TP) documentation.
TP documentation must be submitted in Bahasa Indonesia.

Related party

Under Article 18(4) of the Income Tax Law, related parties are defined as follows:

1. Having 25% or more equity ownership (directly or indirectly or common ownership) with the other party.
2. The participation in management or technology even if there is no ownership.
3. A family relationship exists through either blood or marriage, within one degree of direct or indirect lineage.
   Eg: Relatives, parents-in-law, stepson or stepdaughter, relatives-in-law.

Acceptable Transfer Pricing method

1. Comparable Uncontrolled Price (CUP)
2. Resale price
3. Cost-plus
4. Profit split
5. Transactional net margin

Due dates and respective threshold:

*Statement Letter is to declare on the date on which the Master File and Local File became available.

Please be aware below Warning:
The above contents are digested by Evershine R&D and Education Center in October 2021.
Regulations might be changed as time goes forward and different scenarios will adopt different options.
Before choosing options, please contact us or consult with your trusted professionals in this area.

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E-mail: jkt4ww@evershinecpa.com
or
Contact us by WeChat or Skype or Whatsapp in the day-work-time of Taiwan (GMT+8)
The Engaging Manager from Headquarter
Project Manager Cindy Victoria Speak in Bahasa, English, and Chinese.
Whats App +886-989-808-249
wechatid: victoria141193

or
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