Through APA Assistance, MUC Consulting Promotes Tax Certainty and Minimizes Disputes
JAKARTA. MUC Consulting assisted a taxpayer in the negotiation process of a Unilateral Advance Pricing Agreement (UAPA) with the Directorate General of Taxes (DGT). The negotiation resulted in an agreement on the transfer pricing treatment of affiliated transactions.
The agreement was signed between the taxpayer and the Director of International Taxation at the DGT, Dwi Astuti, on Wednesday, April 15, 2026, at the DGT Head Office.
Through the APA scheme, the taxpayer gains more concrete certainty, particularly regarding how the arm’s length principle will be assessed by the tax authority.
This certainty applies not only to future planned transactions but may also cover prior periods through a roll-back mechanism, provided that no tax audit has been conducted for the relevant fiscal years.
In addition, the APA agreement provides certainty from a monitoring perspective. As long as the taxpayer complies with the agreed parameters, the tax authority will not conduct audits on transactions covered under the agreement. This allows companies to implement transfer pricing policies in a more measured and consistent manner.
Tax Risk Management
From a management perspective, APA serves as an effective tax risk management instrument. With greater certainty, companies can avoid prolonged disputes—including those escalating to appeals at the Tax Court. As a result, businesses can save time, resources, and compliance costs while focusing more on strategic business activities.
Partner of Transfer Pricing at MUC Consulting, Wahyu Nuryanto, stated that his team played a role in assisting the taxpayer throughout the negotiation process with the tax authority.
"We act as consultants supporting taxpayers during the UAPA negotiation process with the Directorate General of Taxes. We are grateful that the process was completed constructively, resulting in an agreement that provides certainty for both parties," he said.
According to him, for taxpayers, a successful UAPA provides tax certainty over affiliated transactions while minimizing potential disputes during the agreement period. This certainty is also crucial in supporting medium- and long-term business planning, as well as improving the quality of tax compliance.
Encouraging Voluntary Compliance
On the other hand, for the tax authority, UAPA offers benefits such as certainty of the tax base, increased voluntary compliance, and more effective transfer pricing risk management through a cooperative and dialogue-based approach.
"This achievement reflects the importance of data transparency, consistency in applying the arm’s length principle, and a shared commitment to building a fair, effective, and sustainable tax system," Wahyu added.
In this process, MUC Consulting’s APA negotiation team consisted of five members led by Wahyu Nuryanto. The team included Transfer Pricing Director Zulhanief Matsani, Senior Manager Tigor Mulia Dalimunthe, as well as Supervisors Anindita Swastika Putri and Septa Dwi Indriyani. (ASP/KEN)
