Indonesia: New transfer pricing requirements | KPMG | GLOBAL
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Indonesia: New transfer pricing requirements include country-by-country reporting

Indonesia: New transfer pricing requirements

New transfer pricing reporting compliance requirements in Indonesia were issued by the Ministry of Finance at the end of 2016, and put into effect reporting and documentation recommendations from the OECD’s base erosion and profit shifting (BEPS) project.


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The guidance issued by the Minister of Finance is Regulation No. 213/PMK.03/2016, and it requires the preparation of three documents regarding related-party transactions:

  • The Master file, containing general information about the taxpayer group 
  • The Local file, containing specific information on operations in Indonesia
  • The country-by-country (CbC) reporting file, containing detailed financial and other information on each of the members of the group

The Master file and the Local file must be available, upon request, four months after the fiscal year-end, and must be available in either the Bahasa Indonesian language or English language (for taxpayers having approval to maintain their bookkeeping in the English language, it must be accompanied by a Bahasa Indonesian translation). The CbC report submission is due within one year after the end of each fiscal year.


Read a January 2017 report [PDF 3.17 MB] prepared by the KPMG member firm in Indonesia

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