Transfer Pricing Advisory
Transfer Pricing Advisory
We advise our clients on the scope and application of transfer pricing legislation and policies in Indonesia, and the documentation and reporting obligations in relation thereto.
We also assist our clients with the preparation of the Master File and Local File.
The Master File provides for an overview of information relevant for the transfer pricing within the group as a whole, such as the transfer pricing policy of the entire group, the composition and organisation of the group, an overview of the allocation of activities, intangible property of the group dan financial activity of the group.
While the Local File contains an overview and description of actual intra-company transactions and the way the internal transfer prices have been determined for such transactions.
Intercounbix – our team of specialists work with our clients to provide cutting edge services in the field of transfer pricing to meet their business objectives.
Transfer Pricing Design
We support our clients with the design and development of their transfer pricing policy for determining the internal prices for goods delivered and services rendered within the group.
The design of the transfer pricing policy of our client requires comprehensive insight in the business characteristic of our client, the value chain within the group, and the function, asset, and risk analysis of all distinguishable parts of the group.
After an analysis of available data and relevant facts and circumstances, we translate this into a fiscally acceptable transfer pricing strategy
Transfer Pricing Review
We reviewed the Transfer Pricing Documentation to mitigate the tax compliance risk of transfer price examination described in the Transfer Pricing Documentation in accordance with tax regulations in Indonesia (PMK 213/PMK.03/2016).
Advanced Pricing Agreement (APA)
If our clients wants 100% certainty in advance about transfer pricing related topic, we can represent our client in the negotiation with the DGT for obtaining an Advance Pricing Agreement (APA).
Taxpayers can only obtain an APA if it can demonstrate that the transfer price used or the transfer price are intended to be used, are consistent with the arm’s length principle.
Related to MAP we also help our clients to find the best solution in solving problems that arise in the implementation of Tax Treaty and international tax disputes related to transfer pricing.
Country by Country Reporting (CBCR)
We assist our clients with the preparation of CBC reports. CBCR is part of a suite of international measures aimed at combating tax avoidance. It achieves this through comprehensive exchanges of information between participating jurisdictions.
According to Indonesian tax law, multinational companies as a parent entity with a consolidated turnover of Rp11 trillion or more, must submit a country report to the tax authorities in the country where the designated reporting entity is resident for tax purposes.
Co-operation With Third Parties
In the preparation of Local File, we work with third parties (TP Catalyst from Bureau Van Dijk – A Moody’s Analytics Company) which has a database containing company profiles and financial reports of companies located in the Asia Pacific region, which provides the data needed in the preparation of Local File.
how can we help you?
Contact us at the Intercounbix office nearest to you or submit a business inquiry online.
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