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
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.
Define the rules of engagement. We draft, negotiate, and ratify your mandatory “Peraturan Perusahaan” (PP) with the Manpower Office, creating a legal framework that balances employee rights with corporate goals.
- Legally Ratified: Official approval from the Ministry of Manpower.
- Customized Policies: Tailored rules for attendance, discipline, and benefits.
- Termination Protection: Clear legal grounds for discipline and discharge.
Strengthen your balance sheet without a cash injection. We manage the complex legal conversion of intercompany loans into company shares, optimizing your “Debt-to-Equity” ratio and improving your tax standing.
- Balance Sheet Optimization: Instant improvement of financial health ratios.
- Tax Efficiency: Resolving "Thin Capitalization" risks.
- Strategic Financing: Converting parent company support into permanent equity.
Precision payroll for a digital era. We manage your monthly salary calculations, tax (Art 21) withholdings, and BPJS reporting through the 2026 Coretax system, ensuring every employee is paid accurately and on time.
- Coretax Integrated: Seamless Art 21 tax filing and ID billing.
- Benefit Management: Automated BPJS Kesehatan and Ketenagakerjaan calculations.
- Confidential & Secure: Professional handling of executive salary data.
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.
The global blueprint for your group. We draft a high-level Master File that describes your global business model, intangibles, and financing in a way that aligns with Indonesian disclosure standards.
- Group-Wide View: Comprehensive global organizational structure.
- Intangible Focus: Documentation of global IP and DEMPE functions.
- MoF Compliant: Formatted specifically to meet Indonesian PMK-172 rules.
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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Tell us about your company and we are ready to Transforming Your Vision Into Results
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