Page 2 - Newsletter (An Update on CbC Reporting Regulations in Indonesia)
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DDTC Tax Newsletter 02 I Jan 2018 Page 2 of 2
An Update on CbC Reporting Regulations in Indonesia
Notification obligation release a list of treaty partner countries that have a treaty
in place containing an exchange of information clause,
Regardless whether a domestic taxpayer is required to qualifying competent authority agreements (QCAA), and
submit a CbC Report or not, all taxpayers who are member have QCAA but CbC Reports are unobtainable by the DGT.
entities of a group or have related party transactions, are
Upon the announcement of the list of such countries,
obliged to submit a notification concerning CbC Report
domestic taxpayers delegated with the CbC Report
to the DGT.
obligation has 3 months to submit CbC Report. If within
The Notification in question contains a statement that period, the taxpayer fails to submit a CbC Report, the
about the identity along with the jurisdiction of the Directorate General of Taxes shall send a formal request
particular member entity of the group that is to conduct letter to said taxpayer, and grant a 30-day extension since
the CbC Report. This is intended to facilitate the DGT the date of the request letter.
in requesting CbC Reports through cross-border
information exchange mechanism. XML Schema Electronic Format
Having submitted the notification, the taxpayer
PER-29 provides that the submission of CbC Reports
will be given a receipt that can be used as a substitute
must be conducted electronically i.e. with Extensible
for CbC Report to be attached to the Annual Corporate
Markup Language (XML). In line with the international
Income Tax Return. Said notification should be submitted
standards as prepared by the OECD, it has been agreed
electronically to DGTonline platform or manually should
that CbC Reports should be submitted in the same
the online platform malfunction. The time limit is 16
electronic format in every country, namely XML Schema.
months since the end of the tax year, for CbC Report 2016
This is to facilitate automatic exchange of information
or 12 months after the end of the tax year, for CbC Report
between countries. The first CbCR information exchange
2017 and so forth.
is expected to take place in July/September 2018.
Publication of treaty partner Countries that The OECD website reports that as of 19 December
are unqualified for information exchange 2017, there are 68 countries that have signed the
Multilateral Competent Authority Agreement on the
Exchange of CbC Reports (CbC MCAA).
To provide legal certainty of CbC Reporting obligations
by domestic taxpayer that are not parent entities, PER-
29 stipulates that at the end of each year the DGT will
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B. Bawono Kristiaji, S.E., M.S.E., MSc., ADIT Jl Bulevar Kelapa Gading LA3 No.1
Partner, Research and Training Services at DDTC Summarecon, Kelapa Gading, Jakarta Utara 14240 - Indonesia
contact: [email protected] Phone: + 62 21 2938 5758 I Fax: + 62 21 2938 5759
Romi Irawan, S.E., M.B.A., LL.M Int. Tax The authors would like to thank Darussalam (Managing Partner
Partner, Transfer Pricing Services at DDTC at DDTC), Danny Septriadi (Senior Partner at DDTC) for their
Contact: [email protected] valuable input, insight and constructive discussions.
Yusuf Wangko Ngantung LL.B, LL.M Int. Tax., ADIT The information herein is for general purposes only and is not intended to address the
Senior Manager, Transfer Pricing Services at DDTC circumstances of any particular individual or entity. This content should not be used as
reference for consultation with professional advisors.
Contact: [email protected]
© 2018 DDTC is a research and knowledge based taxation institution and a centre of a
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Senior Manager, Transfer Pricing Services at DDTC We were established in 2007 by Indonesian well known taxation experts, Darussalam and
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