We provide Transfer Pricing Documentation Services Indonesia, Transfer Pricing in Indonesia is one of the critical taxes issues for growth oriented businesses having international businesses wherein substantial senior management’s time and attention is necessary. Regardless of their size, organizations need an efficient and trustworthy Transfer Pricing policy, which takes into mind the Company overall business strategy and operating structure.
Our Transfer Pricing team using its have experience and demonstrated capabilities offers comprehensive solutions in areas such as Transfer Pricing Documentation, Transfer Pricing assessments and other value added services such as Benchmarking services, Drafting of Inter-company agreements etc.
We understand that the Company entered into transactions with its related parties during the year 2016. Pursuant to Minister of Finance Regulation Number 213/PMK.03/2016 about the documentation and/or the additional information which should be kept by the tax payer who has transaction with the related party and procedures of the Transfer Pricing Documentation (the “PMK-213”), then to support its related party transactions, the Company needs the Transfer Pricing Documentation.
Given the above understanding, the scope of engagement, which we will deliver, will cover the following the Transfer Pricing Documentation.
Pursuant to PMK-213, the taxpayers that are:
- has the Revenue more than Rp.50,000,000,000; and
- entered into transactions with related parties with the aggregated value of transactions exceed Rp.20,000,000,000 in 1 (one) year for tangible goods transaction, are obligated to prepare documentations for those transactions.
The scope of our services consists of following:
1. Preparation of Master File
2. Preparation of Local File
a. Functional Analysis
b. Industry and company analysis
c. Selection of the most appropriate transfer pricing methodology
d. Application of the most appropriate transfer pricing method for Company’s related party transactions
3. Preparation Transfer Pricing Report
Our transfer pricing report will contain the following:
- Background of the Company and its Associated Enterprises;
- Industry and company analysis
- Functional Analysis to document the Functions, Risks and Assets;
- Comparability/Benchmarking analysis to prove the Arm’s Length nature deployed of International Transactions entered into between Associated Enterprises.
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Transfer Pricing Documentation Services Indonesia
Reff: Dirjen Pajak KemenKeu