Transfer Pricing Disputes and Moot Court Simulation – Batch 3

When:
Batch 3 (1 December 2018)

Activity Time:
09.00 a.m. – 05.00 p.m.

Where:
DDTC Academy
Menara DDTC (1^st Floor)
Jl. Raya Boulevard Barat Blok XC 5-6 B
Kelapa Gading Barat, Kelapa Gading
Jakarta Utara, DKI Jakarta,14240 – Indonesia

Course Level:
This course is advanced level. Participants enrolling in this course are expected to have good understanding of transfer pricing principles. We recommend you to participate in our Intensive Course: Transfer Pricing – Executive Class. For more details, please click here!

Investment:
IDR 2.500.000

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

In recent years, DGT has issued several domestic tax regulations concerning transfer pricing, i.e. PMK 213/PMK. 03/2016 Guidance on types of additional documents and/or information which are mandatory to be stored by Taxpayers conducting transactions with related parties, and the procedures. The transfer pricing audit standards are governed in DGT regulation No. PER-22/PJ/2013 (TP Audit Standard) and the implementing instructions for tax auditors are set out in DGT Circular Letter No. SE-50/PJ/2013 (Auditor’s TP Audit Manual), ‘Application of Arm’s Length Principle Rules’ set out in DGT regulation No. PER-43/J/2010 (issued on 6 September 2010) last amended by PER-32/PJ/2011 (issued on 11 November 2011).

Transactions with related parties most likely will lead to disputes with the DGT. Tax dispute resolution at the judicial level is first settled in the Tax Court. Accordingly, taxpayers wishing to challenge the DGT’s decision should be prepared to commence the appeal process to the Tax Court at the very least. To elevate the understanding on how to prepare the appeal process to the Tax Court, hereby, DDTC Academy provides practical course “Transfer Pricing Disputes and Moot Court Simulation”.

This course will discuss mainly those several domestic tax regulations which has been issued by DGT and will also discuss the draft of new KUP Law (General Tax Provisions and Procedures Law) which includes TP Doc as an attachment of CIT return. Such provision would affect the evidentiary procedures in the tax court. Further, Indonesia’s TP landmark supreme court cases will also be discussed, such as ITM and Kraft Indonesia. The two cases discuss the comparability issues in TP. Other TP cases, both from Indonesia and overseas will be covered in this course.

This course is designed particularly to cover all issues that may arise based on domestic and international transfer pricing disputes trends. Furthermore, various techniques for appeal preparation e.g. documenting facts, building logic, as well as presenting the arguments will be covered both in classroom and moot court simulation.

Topics Covered:

• The judicial procedures in tax court
• Overview of the legal framework of Indonesia’s and International Transfer Pricing
• Indonesia’s and International Transfer Pricing cases
• Transfer Pricing case study
• Moot court simulation (including of drafting of “Letter of Appeal”)

Who should attend?
The course is suitable for CFOs, tax directors, tax managers, accountants working in companies performing financing activities across all industries, treasury managers, chartered accountants, financial controllers and analysts, internal and external auditors, tax experts and lawyers.

Our Excellence:

• DDTC is a research and knowledge based institution.
• DDTC was given an award by International Tax Review’s World Tax and World Transfer Pricing 2018 acknowledging our Managing Partner, Darussalam as a leading adviser and DDTC as a recommended firm in Transfer Pricing.
• Senior Partner DDTC, Mr Danny Septriadi, was selected as one of the World’s Leading Transfer Pricing Advisers 2017 by Expert Guides (one of the most trusted resources for international buyers of legal services).
• DDTC has published a number of bestselling transfer pricing books.
• Managing Partner and Senior Partner DDTC have been acknowledged as expert contributors for reputable national and international academic journals.
• Highly rated instructors. Our instructors are experienced trainers who consistently receive the highest rating for their presentations, have multidisciplinary educational background and hold world-class international certification, as follows:
  • 2 PhDs from Claremont Graduate University (USA) and the University of New South Wales (Australia);
  • 9 Master’s Degrees in International Taxation from leading universities abroad;
  • 1 Bachelor’s Degree (LL.B) in Taxation Law (Fiscal Recht from Leiden University, The Netherlands);
  • 4 Advanced Diplomas in International Taxation (ADIT) of the Chartered Institute of Taxation (UK);
  • 1 Diploma in International Taxation of International Tax Center, Leiden University, The Netherlands;
  • 11 Certificate Holders of International Tax Certificate from the Chartered Institute of Taxation (UK);
  • 15 Certificate Holders of Transfer Pricing from the Chartered Institute of Taxation (UK).

• Our topics always keep up with the latest taxation issues which are published via books, InsideTax (a semi-journal magazine), working papers, journals and DDTC News.
• Interactive training and case studies models.
• Up-to-date materials, relevant course contents and supported by a dedicated tax research team.
• To offer high quality training programs, DDTC equips its resources with a library that has more than 2,500 collections pertaining to transfer pricing, international & domestic taxation, and other subjects from reputable publishers and authors.

Our Facilities:

• Menara DDTC, new office building with new atmosphere, the best and most comprehensive professional training facilities (theater classes, cozy room, new concept and modern design, moot court simulation room, free Wi-Fi, modern facilities, etc.).
• Library access of more than 2,500 books and taxation journals.
• Exclusive training kits (goodie bag, notepad, pen).
• Getting “Kartu Peserta Training” that can be used as a discount card to re-attend our next training programs.
• Getting “Certificate of Training”.
• Lunch and coffee break are provided.