Indonesia’s transfer pricing regulations focus on determining the price in a transaction between parties having a “special relationship”—defined to include a capital participation of 25% or more, control through management or technology, or a “family relationship.”
Under the transfer pricing rules, Indonesian taxpayers are required to disclose additional details of their related-party transactions in their annual tax returns and to declare that transfer pricing documentation is available.
Also, the Directorate General of Tax has informally expressed an intention to adopt a country-by-country reporting requirement that reflects the base erosion and profit shifting (BEPS) project recommendations of the OECD. However, it is uncertain at this time whether country-by-country reporting will be formally implemented in Indonesia.
Read a 2016 report [PDF 5.29 MB] prepared by the KPMG member firm in Indonesia: Transfer Pricing: Frequently Asked Questions
The FAQs addressed in this report are:
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