Transfer Pricing
Protect your global profits and eliminate audit risks. We provide a comprehensive, three-tiered defense strategy—Master File, Local File, and CbCR—specifically tailored to Indonesia’s 2026 “Ex-Ante” mandates and Coretax monitoring.
- Ex-Ante Compliance: Price-setting documentation for the 2026 tax year.
- Audit-Hardened: Benchmarking that withstands aggressive DJP scrutiny.
- Global Alignment: Seamlessly integrating local files with HQ global reports.
Transfer Pricing
From startup to M&A and global expansion, we streamline your journey. Optimize accounting, cut costs, boost productivity, and handle legal challenges effortlessly. Your success starts here!
About
Transfer Pricing in Indonesia is no longer just a year-end report; it is a mandatory preliminary analysis for all related-party transactions (RPTs). Our service ensures that your intercompany pricing—whether for goods, services, royalties, or loans—is backed by the “Arm’s Length Principle” (ALP) using the latest 2026 geographical comparability standards.
Why Choose Our Transfer Pricing Services?
Indonesia is one of the world’s most assertive TP jurisdictions. We utilize premium global databases (like Orbis and KT Mine) combined with deep local knowledge of the DJP’s “risk-based” audit triggers. We don’t just draft documents; we build a defensible economic narrative for your business.
Benefits of Our Service
Zero Penalty Strategy: Avoiding the 100% “Deemed Dividend” reclassification of TP adjustments.
Geographical Precision: Prioritizing Indonesian and regional comparables as required by PMK-172.
Efficiency: Unified documentation that satisfies both Indonesian Law and OECD guidelines.
FAQ for Transfer Pricing
Who is mandatory to prepare TP Doc?
What if we are below the threshold?
What is the "Ex-Ante" approach?
Is the CbC Report (CbCR) required for all?
What are the common TP methods?
Can we use a "Single-Year" analysis?
Do you handle "Intangible" (Royalty) TP?
What is a "Secondary Adjustment"?
Can we apply for an APA?
What is the deadline?
General Manager, TCG Thailand
Other Services
Protect your intellectual property and commercial interests. We draft and review high-level service agreements—from management fees to technical assistance—that are legally sound and compliant with Indonesian tax and labor laws.
- Intercompany Precision: Structuring "Management Service Agreements" for TP.
- IP Protection: Clear clauses for trademarks, trade secrets, and software.
- Dispute Avoidance: Jurisdiction and arbitration clauses that protect you.
Turn potential into performance. We design customized Key Performance Indicators (KPI) and Management by Objectives (MBO) frameworks that align your Indonesian team’s daily output with your global corporate vision.
- Data-Driven Growth: Objective metrics to measure success and ROI.
- Strategic Alignment: Linking individual tasks to company-wide targets.
- Performance Culture: Rewarding excellence with transparent, fair systems.
Keep your corporate structure agile. Whether changing directors, shifting address, or increasing capital, we manage the formal “Akta Perubahan” process to ensure your changes are legally recognized by the state.
- Official Notary Network: Direct access to trusted Indonesian Notaries.
- Fast Approval: Rapid AHU (Ministry of Law) validation.
- Data Synchronization: Automatic updates to your OSS and Tax profiles.
Don’t face the tax man alone. We provide end-to-end guidance during field and desk audits, ensuring your documentation is presented legally and your rights as a taxpayer are fully protected.
- Evidence Preparation: Building the "Working Paper" to defend your tax positions.
- On-Site Representation: Handling the face-to-face meetings with tax auditors.
- Outcome Optimization: Technical rebuttals to the SPHP (Audit Result Notification).
Secure your financial future with a rigorous examination of your accounts under the new 2026 SAK EP standards. We turn your data into a verified, high-integrity financial report that speaks the language of global investors.
- SAK EP Expertise: Master of the 2026 private entity standards.
- Investor Ready: Perfectly formatted for shareholders and global HQ.
- Process Driven: Thorough testing of revenue, expenses, and assets.
Secure your right to work in Southeast Asia’s largest economy. We manage the dual-layer approval process—Manpower and Immigration—to deliver your Working KITAS with maximum speed and zero technical errors.
- Dual-Authority Management: Coordinated RPTKA (Manpower) and ITAS (Immigration) filings.
- Role Optimization: Expert guidance on job titles allowed for foreign workers.
- Automated Renewals: Proactive tracking to ensure your permit never expires.
WTC 5, 12th floor. Jl. Jenderal Sudirman No.Kav. 29-31, RT.8/RW.3, Kuningan, Karet, Kecamatan Setiabudi,
Kota Jakarta Selatan, Daerah Khusus Ibukota
Jakarta 12920
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