Ensure Compliance with Indonesian Transfer Pricing Regulations
Transfer pricing in Indonesia is subject to strict regulation and heightened scrutiny by the tax authorities. Businesses engaging in related-party transactions must comply with the arm’s length principle and maintain comprehensive Transfer Pricing Documentation (TP Doc).
Our transfer pricing services in Indonesia help companies manage risk, ensure regulatory compliance, and defend their transfer pricing positions during tax audits.
Why Transfer Pricing Compliance is Critical in Indonesia
The Indonesian government actively enforces transfer pricing regulations and has adopted key elements of the OECD BEPS Action Plan, including Action Plan 13 on documentation.
Under Indonesian Income Tax Law:
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Taxpayers must apply the Arm’s Length Principle (ALP)
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Transfer Pricing Documentation must be prepared annually
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TP documentation availability must be declared in the Annual Corporate Income Tax Return
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Non-compliance may trigger special tax audits and significant sanctions
Failure to properly implement transfer pricing rules exposes companies to reassessments, penalties, and prolonged disputes.
The Value of a TGS AU Partners Transfer Pricing Service
Our transfer pricing methodology is grounded in:
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Indonesian Income Tax Law
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Minister of Finance Regulation No. 213/PMK.03/2016
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DGT Regulation PER-11/PJ/2011
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OECD Transfer Pricing Guidelines
Our services include:
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Identification and review of related-party transactions
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Functional and comparability analysis
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Selection and application of appropriate TP methods
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Determination of arm’s length pricing range
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Preparation of Master File, Local File, and CBCR
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Assistance in transfer pricing tax audits
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Advisory on TP disputes and litigation
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Arrangement of Advance Pricing Agreements (APA)
We focus on building defensible documentation and minimizing audit risk.
Our Professional Standards & Responsibility
We uphold:
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Strict confidentiality
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Technical accuracy aligned with Indonesian regulations
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Documentation prepared in Indonesian language as required by law
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Annual compliance monitoring
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Clear audit-ready documentation
Our team continuously monitors regulatory developments and OECD updates to ensure alignment with evolving standards.
Why Choose TGS AU Partners?
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Experienced tax consultants and tax attorneys
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Strong technical expertise in TP documentation and disputes
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Experience handling TP tax audits and litigation
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Deep understanding of BEPS implementation in Indonesia
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Access to international coordination through TGS Global Network (70+ countries)
We provide practical, defensible, and business-oriented transfer pricing solutions.
Industry Expertise
We support companies with domestic and cross-border related-party transactions.
Sectors We Serve:
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Multinational corporations
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Manufacturing and distribution groups
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Service-based companies
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Digital and technology businesses
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State-owned enterprises
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Holding and investment companies
Each engagement is tailored based on transaction complexity and group structure.
Our Office Address
Head Office:
Wisma Staco Lantai 6
Jl. Casablanca Kav 18
Jakarta Selatan 12870, Indonesia
Branch Office:
Jl. Kalpataru No. 33, Ruko Kav. 4
Lowokwaru, Malang 65141
Indonesia
Frequently Asked Questions (FAQ)
Who is required to prepare Transfer Pricing Documentation in Indonesia?
Taxpayers meeting turnover or related-party transaction thresholds under MoF Regulation 213/2016 must prepare Master File and Local File annually.
What are the TP documentation thresholds?
Generally required if annual turnover exceeds IDR 50 billion or related-party transactions exceed specific thresholds.
Is Country-by-Country Reporting (CBCR) mandatory?
CBCR is required for parent entities with consolidated gross turnover of at least IDR 11 trillion or under specific cross-border conditions.
Must TP documentation be prepared in Indonesian language?
Yes. Indonesian tax law requires TP documentation to be prepared in Bahasa Indonesia.
Can you assist during a TP audit?
Yes. We provide full audit defense and dispute resolution support.
