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.
Stay “Invisible” to the tax man. We manage all your monthly withholding taxes (Art 21, 23, 4(2)) through the 2026 Unified Tax Return system, ensuring your payments are on time and your records are flawless.
- Unified Filing: Single monthly "SPT Masa Unifikasi."
- Auto-Withholding: Calculation and ID billing generation.
- Penalty Protection: Proactive payment tracking to avoid interest.
Protect your foreign debt status with expert KPPK attestation. We ensure your corporate foreign debt reporting meets Bank Indonesia’s strict 2026 prudential principles, avoiding costly sanctions and credit rating drops.
- Bank Indonesia Expert: Specialized in PBI No. 16/21/PBI/2014 compliance.
- Agreed-Upon Procedures: Precise attestation of hedging and liquidity ratios.
- Sanction Defense: Guaranteed accuracy to prevent BI administrative fines.
Close your business the right way. We manage the entire liquidation and dissolution lifecycle—from appointing the Liquidator to the final “Deletion” from the Ministry of Law—ensuring all debts are cleared and assets distributed legally.
- Full Asset Disposal: Managed legal distribution to shareholders.
- Creditor Management: Mandatory announcements and dispute resolution.
- Official Dissolution: Final "Deletion of Entity" (Penghapusan) from all state registers.
Personal tax peace for expats and executives. We manage the annual SPT 1770 for your foreign and local staff, ensuring their global income is correctly reported according to the 2026 “Territorial” and “World” tax rules.
- Expat Specialists: Managing the 4-year territorial tax perk.
- Global Income Review: Expert advice on foreign source income.
- March 31 Deadline: Fast and efficient personal filings.
Protect your Board of Directors with formal, signed legal and financial opinions that provide a “Bulletproof” defense for complex decisions. When you face “grey areas” in Indonesian law, our Professional Opinion is your official shield.
- Bulletproof Defense: Signed, formal legal proof.
- Director Protection: Shifts liability to the experts.
- Grey-Area Clarity: Resolves legal contradictions.
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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