DDTC Consulting

AuP tax engagement is intended to identify internal capability to use agreed upon audit standards and procedures. This procedure is similar to audit standards commonly applied by tax authority in Indonesia. In this matter, we will test the bookkeeping of taxation accounting, calculation, and other required procedures. We can also evaluate overall degree of tax compliance. AuP tax engagement is conducted not only to give a strong basis in compiling factual reports of taxation position, but is also designed and conducted to discover whether there are certain tax risks along with the causes.

Establishing prices for transactions between related parties is basic to set and design transfer pricing policies within multinational companies. The whole process typically involves a thorough analysis of the company's structure, transactions, and applicable regulations, followed by the selection of appropriate transfer pricing methods and documentation of the entire process.

Some of our experiences:

• We supported a leading Indonesian telecommunication group in structuring a profit-sharing model for its GPU Cloud Services, applying the right TP methods to ensure compliance and scalability in a complex digital economy landscape.
• We helped a Japanese multinational health and beverage company design a future-proof TP framework, covering goods, services, and royalties.

Transfer pricing is the core of affiliated transactions and will have significant consequences if done incorrectly. With our integrated operational transfer pricing, shift your traditional approach into an efficient and intuitive yet remain in compliance.

Some of our experiences:

• We assisted a leading chemical manufacturer, part of a major South Korean conglomerate, in aligning TP compliance with business realities. As a petrochemical start-up, the company faced early-stage inefficiencies. We adjusted for these operational factors to ensure fair profitability under the right method during its ramp-up phase.
• We helped a infrastructure company, part of multinational group from Thailand, revamp its intragroup service framework, ensuring each service was justified, documented, and priced at arm’s length. This prevented future audit disputes.

Documentation of transfer pricing is a critical compliance requirements for multinational corporation. It ensures that intercompany transactions are conducted at arm's length principle. We will provide your company's TP Doc including master file, local file and country-by-country reporting (CbCR), in line with international and domestic tax law and regulation.

With experience serving over 1,300 companies across more than 150 industries, we prepare approximately 2,000 TP Docs every year. Our approach combines regulatory compliance with deep industry understanding, ensuring each documentation not only meets standards but also supports audit defense and reflects the commercial reality of your business.

Transfer pricing audits are frequently conducted in a cross-border transactions when tax authorities detected anomaly and will lead to an appeal occasionally. In case of disputes, we will defend your position involving strategic and integrated approach based on factual matters of arrangements within your multinational group.

Some of our experiences:

• We represented a South Korean multinational logistics company in a TP dispute over a domestic restructuring, convincing the court that no compensation was required for the spin-off of its operations.
• We defended a leading Indonesian vegetable oil processor in a TP dispute on rebates to affiliates, convincing the court that such incentives were commercially justified under real-world commodity trading practices.
• We defended a palm oil exporter, part of a UK-based multinational energy group, in a cross-border TP dispute. We proved forward pricing was appropriate and expense corrections unfounded, securing a full win in record time at the Tax Court.
• We defended a digital fashion platform, part of a global e-commerce group operating across Asia, Latin America, and Eastern Europe, in a TP dispute on intragroup services. We proved the fees were commercially essential and the court rejected the tax authority’s claim in full.
• We defended a leading Japanese multinational electronics manufacturer in a landmark case regarding trademark, where the Tax Court rejected the tax authority's use of the bright line test.

The strategic and integrated approaches in our dispute resolution services enable clients to navigate through the dispute resolution process via domestic dispute resolution, unilateral/bilateral negotiations with the competent authorities or advance pricing agreements.

Some of our experiences:

• We represented a global textile group in securing Indonesia’s first bilateral APA with the UK, covering royalties and service fees. The agreement clarified profit allocation on IP use and marketing support, setting a key precedent for future cross-border arrangements.
• We assisted a Thailand-based multinational in the coal industry in initiating Indonesia’s first APA process with Thailand. Aiming to resolve recurring disputes over marketing service charges, we simplified the case presentation to bridge regulatory differences and enable more effective negotiations between both competent authorities.
• We represented a multinational packaging company in concluding a bilateral APA between competent authorities. The agreement provided certainty on cross-border transfer pricing, marking a milestone in Indonesia–Switzerland tax cooperation.
• We assisted member companies of a global textile group in concluding a bilateral APA between competent authorities, working alongside a Korean Big 4 firm. The agreement provided certainty on cross-border pricing arrangements.

The latest minister of finance regulation in Indonesia required multinational corporation to conduct preliminary stages in relation to the application of arm's length principle of affiliated transactions. We will prepare a comprehensive report and provide opinions on precautionary measures, including attachments of various evidence collected during the stages.

Our services include VAT document reviews, drafting precedent VAT clauses, advice in relation to mergers, acquisitions and structuring, negotiating VAT positions in relation to contracts, advice on input tax recovery and apportionment methodologies, VAT dispute management, private ruling applications and VAT due diligences.

Different interpretation, income characterisation, and administrative procedure requirements are areas prone to dispute. Hence, we will assist you to comply with withholding tax position, to prevent disputes in the future. Moreover, we are also able to draft private ruling applications, to provide independent analysis or opinion and due diligence of withholding tax.

We will support you in every stage of tax audit and evaluate audit techniques and adjustments conducted by tax authority. We will also assist you in providing written response and represent you when directly interacting with tax authority.

Some of our experiences:

• We assisted a Chinese conglomerate manufacturing home appliances in a VAT and WHT investigation on reimbursements, reframing the issue as administrative and securing a non-criminal settlement that avoided prosecution.
• We defended a prominent Indonesian shipping company in a debt-to-equity swap dispute post-PKPU, proving the share premium was not taxable, which led the court to cancel the correction and set a key restructuring precedent.
• We supported a French multinational beauty and personal care company in a full-scope tax audit, reducing a massive correction by 98%.
• We defended a leading Indonesian automotive distributor in navigating a full-scope tax audit under tight deadlines. By managing data delivery and substantiating key corrections, we helped eliminate significant tax risk and avoid costly disputes.
• We assisted a leading global healthcare company in defending the deductibility of litigation expenses from a commercial dispute. Through a multidisciplinary approach and timely audit handling, the tax authority accepted the claim with no adjustments.

During tax objection, we will represent clients to support their tax positions by rebutting tax authority assessment. Where the dispute involves factual matters, we will ensure that all facts or documents requested during tax audit could be submitted or re-submitted during objection. Failure to provide sufficient facts during audit or objection could disallow such facts to be presented during appeal. As for legal dispute, we will employ our signature tax research techniques to support clients’ objection.

Some of our experiences:

• We represented a leading Japanese electronics manufacturer in challenging a reclassification of transactions subject to WHT. By categorizing disputed entries and presenting sample-based evidence, the Tax Court partially granted the company’s appeal.
• We defended a Chinese multinational consumer electronics company in a PE tax crime case, proving misidentification and reframing the issue as administrative, not criminal, leading to a settlement without prosecution.
• We defended a Thai conglomerate in poultry industry in a VAT dispute over rejected chickens, showing the sales were part of normal operations and exempt. The tax authority dropped the correction at objection stage.
• We defended a telecom infrastructure company in a VAT dispute on business separation, proving the transaction was not subject to VAT. The court ruled fully in favor of the taxpayer.
• We represented a leading South Korean multinational electronics company in a complex WHT dispute, where management fees were misclassified as gifts. Acting as intermediary with the tax authority, we secured full cancellation of the proposed adjustment.

Whenever a cross-border taxation dispute occur with a taxpayer of a tax treaty partner of Indonesia, an option to resolve the dispute through MAP is worth to review. DDTC will integrate its team of experts to provide strategy and if necessary, team up with the other country’s team to seamlessly support client’s best interest. We will employ its unique assets of its team and its credentials to help support the client’s position.

Some of our experiences:

• We represented a leading South Korean multinational electronics company in concluding bilateral MAP between competent authorities regarding dispute of royalty payments. By proposing a simplified approach, tax assessment under dispute is reduced to half.
• We assisted a subsidiary of a leading Japanese automotive manufacture in continuing initial MAP requested by the company between competent authorities regarding royalty dispute. By concluding MAP, we succeed to eliminate double tax and dismissed ongoing appeal in the Tax Court.

Our tax attorneys work in teams to provide practical advice on high profile disputes. We have represented our clients in some of the most significant tax disputes in the Tax Court including tax law suit and tax appeal. We have also assisted clients in filing civil review to the Supreme Court. Through our experience in many leading tax cases, clients continue to turn to us for strategic advice.

Some of our experiences:

• We defended a leading Indonesian mining contractor in a major tax appeal on depreciation and cost treatment, using an operational video to illustrate business reality. This led to a significant reduction in final tax due.
• We represented a Finnish multinational vertical transport provider in a dispute on revenue recognition, proving that percentage-of-completion was appropriate, leading the court to fully overturn the tax authority’s correction.
• We defended the Indonesian arm of a leading Korean multinational logistics company in dual tax appeals. By applying sample-based evidence and clarifying timing rules, most corrections were canceled, eliminating nearly all potential tax risk.
• We represented the Indonesian arm of a global e-commerce group in a major tax appeal involving the treatment of shipping costs. By demonstrating consistent pricing logic and regulatory compliance, the Tax Court canceled all proposed adjustments.
• We defended a prominent Indonesian palm oil industry in overturning audit corrections on CIT and VAT related to receivable flows and input tax claims. By applying sample-based testing and clear arguments, the Tax Court canceled all material adjustments.

For individuals focusing on business expansion, tax administration could be troublesome and in some cases, it may impede taxpayers. Find out more about how you can manage your tax administration, in particular for ID Registration and De-registration, effectively and efficiently without setting your business aside.

There is more to preparing tax return than just filling in the blanks. We take a further step in that we conduct thorough observation on your conditions that apply in the fiscal year. Our vast experience says that this commencement should save you time and money by avoiding disputes with the DGT. Our key action is analysis on your business and circumstances and adjusting them with tax liability as the result.

Disputes may arise for a number of reasons. However, well-prepared and presented case has significant role to stand your ground. We shall assist you to identify your needs, enrich your stand and execute the planning to present your case in well-mannered preparation.

Lack of guidelines in interpreting tax regulations in Indonesia has the potential to result in tax risks. To minimize such risk, we will assist you in compiling taxation opinion (taxation analysis). Our analysis is conducted in accordance with strict research procedures, and supported by databases originating from Tax Court Verdict and Supreme Court Verdict which have been comprehensively compiled and codified.

To ensure alignment with the changes in corporate restructuring and to optimise tax effect in structuring the transactions, it is advisable to review the tax law related consequences of any decisions and consider all tax efficient strategies to obtain those results. 

We provide reliable and innovative solutions required to maximise our clients’ value which enables them to accomplish the best possible outcome through our tax structuring and planning advisory. Our tax structuring and planning advisory is tailored to the client and fine-tuned to the precise needs of their business.

Some of our experiences:

• We helped an R&D center, a part of a multinational South Korean group, secure a 97% tax refund after audit. By clarifying their CIT position with legal proof and technical facts, we resolved an issue on misapplied SME tax regime before it escalated.
• We advised a digital asset platform on the tax treatment of crypto transactions, including stablecoins and digital bonds—bridging regulatory gaps and shaping compliance in a fast-evolving ecosystem.
• We advised an agribusiness group with entities across Indonesia, Malaysia, and Singapore on a cross-border debt-to-equity swap. Our team designed a tax-compliant structure to minimize risk and optimize capital.
• We advised a international tobacco group on settling intercompany debt through capital reduction, ensuring the transaction met tax and legal standards while improving liquidity without triggering tax exposure.