Exclusive Seminar: New Regime in Transfer Pricing Documentation Requirements in Indonesia

When:
Wednesday, 1 February 2017

Activity time:
08.30 a.m. to 01.00 p.m

Where:
Sumba A & Sumba B Room, Borobudur Hotel
Jl. Lapangan Banteng Selatan, PO Box 1329
Jakarta 10710, Indonesia

Investment:
FREE!

Registration is closed

Background:
Since the release of the OECD final reports on Action Plan on BEPS in 2015, including Action 13 regarding guidance on transfer pricing documentation and country-by country (“CbC”) reporting, many countries have reacted through draft or enacted legislation. CbC reporting is part of the minimum standard in the Action Plan on BEPS that has been agreed to by G20/OECD member countries for consistent implementation in each country. Under the standard, a multinational enterprise (“MNE”) group that meets a certain revenue threshold is required to file a CbC report consisting of tax jurisdiction-wide information relating to the global allocation of the income, the taxes paid and certain indicators of the location of economic activity among tax jurisdiction in which the MNE group operates.

As part of Indonesia’s commitment to the implementation of the standard, the Ministry of Finance released on 30 December 2016, Minister of Finance Regulation No. PMK-213/PMK.03/2016 (“MoF 213/2016”), the much-anticipated regulations on CbC reporting and its corresponding updates to transfer pricing documentation requirements. MoF 213/2016 brings clarity to the transfer pricing documentation legal framework. Previously, transfer pricing documentation requirements are only regulated by way of Directorate General of Tax (“DGT”) Regulations, which is not mandated directly by the Law.

This exclusive seminar will discuss and explain more comprehensive about the new regime in transfer pricing documentation requirements in Indonesia.

Topics covered:

• The linkage between BEPS Action 13 and PMK 213/PMK.03/2016;
• The types of transfer pricing documentation in accordance with the PMK 213/PMK.03/2016;
• Threshold of income and/or the value of transactions which are required to prepare transfer pricing documentation;
• Ex-ante approach and contemporaneous documentation in transfer pricing analysis: arm’s length behavior;
• Administrative and filing in Annual Corporate Income Tax;
• Next step and implementation: critical point and the issues.