Transfer Pricing Services

Transfer pricing has been established by the Directorate General of Taxes (DGT) as a specific area where enforcement is increased for compliance purpose

Many issues may arise based on domestic and international transfer pricing disputes trends. Consequently, there are needs for various techniques for appeal preparation e.g. documenting facts, building logic, as well as presenting the arguments and has to be supported by strong reasoning why certain nominal amount is decided.

Transfer Pricing Documentation

We will help clients to provide transfer pricing documentation for related party transactions in accordance with requirement of the Indonesian tax authority and the OECD Transfer Pricing Guidelines.

Benchmarking Analysis

Benchmarking analysis are the critical part in preparing a transfer pricing documentation.

The service includes searching Potential Comparable data, preparing feasibility study to determine the arm’s length price and manual review to test the arm’s length nature of the related party transactions.

Transfer Pricing Planning and Advisory

With proper planning, the client should be able to uphold its argument about the pricing methodology during the tax audit process. We provide transfer pricing advice for restructuring, review of company’s structure from transfer pricing perspective and general advice on transfer pricing.

We also provide strategic advice on the group structure as well as assistance in conducting business structure review, especially on the related party transactions, in accordance with the Indonesian tax regulations and Transfer Pricing guidelines.

We assist in the Mutual Agreement Procedure for transaction with a tax treaty country and get legal certainty for future related party transactions through planning and/or Advance Pricing Agreement (“APA”).

Transfer Pricing Disputes Resolutions

We assist client in presenting the arguments of the transfer pricing documentation for the purpose of tax audits, objections and appeals.

In the event of disputes or tax authority enquiry, we can help our client to develop a defensive strategy that would strengthen your transfer pricing position based on relevant local and international regulation.