Transfer Pricing Documentation

Transfer Pricing Documentation

13 – 15 November 2017

Activity Time:
09.00 am – 05.00 pm

PT Sinar Agung Prasadikindo (SAS)


Romi Irawan

Romi Irawan

Cindy Kikhonia Febby

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Past In-House Training

Domestic Tax
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Domestic Tax
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3, 4, 5 September 2019

Diskusi Perpajakan atas Transaksi Hubungan Istimewa antara AP1 dan Anak Perusahaannya
27 – 28 August 2019

Understanding Transfer Pricing
30 July 2019

Tax Audit in Mine Industry
24 June 2019

Transfer Pricing Documentation
29 January 2019

Domestic Tax & Transfer Pricing
24 – 25 January 2019

Tax Planning for AP I – Subsidiaries
27 – 28 December 2018

Domestic Tax
19 – 20 December 2018

Customs Update 2018
6 December 2018

Domestic & International Tax Planning
3 December 2018

Transfer Pricing Documentation
21 – 22 November 2018

Pelatihan Tax Treaty
14 – 16 November 2018

Tax Sharing
14 November 2018

Bedah Tuntas OECD Transfer Pricing Guidelines 2017
3 November 2018

Tax Sharing
22 October 2018

Transfer Pricing Documentation, Tax Audit, and Fiscal Reconciliation
22 – 24 October 2018

Domestic Tax
18 – 19 September 2018

Transfer Pricing Documentation
23 – 24 July 2018

Tax Audit, Corporate Income Tax (CIT) and Tax Planning
18 – 20 July 2018

Transfer Pricing Documentation
17 – 18 July 2018

Tax Planning in Connection with the Business Activities of Angkasa Pura I
28 March 2018

Introduction, Fundamental and Trends in Transfer Pricing and Advanced Discussion of PMK 213 and Update on CbC Reporting Regulation PER 29
21 March 2018

Tax on E-commerce
7 March 2018

Persiapan Pembuatan SPT PPh Badan 2017 dan Update Peraturan Pajak Terkait
27 February 2018

Transfer Pricing Documentation
13 – 15 November 2017

Withholding Tax & Value Added Tax
13 – 14 November 2017

Konsep Dasar Perjanjian Penghindaran Pajak Berganda (P3B), Pengampunan Pajak, dan Metode Analisis Kebijakan Fiskal
6 – 8 November 2017

Customs Update
10 November 2017

Intensive Course – Transfer Pricing
22 – 24 August 2017

Transfer Pricing
14 – 16 August 2017

Selected issues in International Tax, Transfer Pricing (PMK 213), Domestic Tax and Update
14 May 2017

Identifikasi dan Mitigasi Risiko Penerimaan Negara dari Sektor Pajak
12 – 13 April 2017

Transfer Pricing Documentation and CbC Reporting – Indonesia: An overview MoF 213/2016 and Next Steps
13 March 2017

Transfer Pricing Documentation and CbC Reporting – Indonesia: An overview MoF 213/2016 and Next Steps and Update Tax Rules
7 March 2017

Transfer Pricing Documentation and CbC Reporting – Indonesia: An overview MoF 213/2016 and Next Steps
22 February, 1 & 2 March 2017

Refreshment for Basic Tax Compliance
22 February 2017

Update FATCA
21 December 2016

19 Desember 2016

Outlook, The General Tax Revision of General Provisions and Tax Procedures Law & BEPS implementation in Indonesia
24 November 2016

Tax Update in Regards with All Taxes Audit / Pemeriksaan Khusus & Rekonsiliasi Pajak – Discussing
17 November 2016

Pengampunan Pajak & Mediasi
14 – 16 November 2016

Basic Tax Compliance untuk Perbankan
8 – 9 November 2016

Transfer Pricing
23 – 24 September 2016

Holding Company Structure and International Tax Planning
25 August 2016

Domestic Tax
22 August 2016

Basic Compliance, WHT, VAT and Corporate Income Tax
25 – 28 July 2016

Tax Audit, Tax Court and Basic Transfer Pricing
16 – 23 June 2016

Tax Talk Digital & Marketing Scheme Telkomsel
21 June 2016

Domestic Tax, International Tax and Transfer Pricing
20 – 23 June 2016

Perlakuan Pajak untuk Industri Jalan Tol
2 – 3 June 2016

International Tax
2 June 2016

International Tax
28 April 2016

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Thursday, 25 October 2018

Activity Time (per batch):
09.00 am – 05.00 pm

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

Course Level:

IDR 3.000.000

Beneficial Owner is one of the most prominently applied concepts in tax treaties. The concept is used to limit the benefits provided under tax treaties, in the form of a reduced withholding tax on dividends, interest and royalties. In practice, the term has been adopted in most tax treaties concluded worldwide, however it has been defined in none. This has given rise to difficulties in interpreting beneficial owner, which in turn results in numerous disputes around the globe particularly in tax treaty shopping scenarios. As beneficial owner is a unique tax treaty concept applied in most tax treaties, understanding the key judicial interpretations and recent development in this area (including BEPS reports and update on the OECD Commentaries) is essential for international practitioners.

Topics Covered:

  1. Base case:
  • What is treaty shopping?
  • Conduit companies
  • Agents and nominees
  1. Analysis on key judicial interpretations: Indofood, Prevost, and Velcro;
  2. The role of certificate or residence/domicile: Administrative vs substantive tax treaty requirement;
  3. Analysis on new Indonesia – Netherlands tax treaty protocol;
  4. History of the beneficial owner concept:
  • Subject to tax concept as alternative in early tax treaty negotiations.
  • OECD Model Tax Convention 1977 – 2014
  1. Indonesia cases overview;
  2. Recent developments in OECD BEPS project: Limitation on benefits provision and principal purpose test;
  3. The relationships and differences between the concept of beneficial owner in tax treaty, tax evasion, and money laundering.

Who should attend?
The course is suitable for company staff, student, 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.

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