Tag
#Arm’s Length Principle
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articleDiffering Tax Office Perspectives: Fueling Uncertainty in Domestic Corresponding Adjustments
Domestic Corresponding Adjustment is believed to be an effective solution to eliminate double taxation related to transfer pricing disputes that occur across taxpayers' domicile. However, in practice, the Domestic Corresponding Adjustment process is often hindered by different Points of View (POV) among tax offices.
Jul 5, 2024
articleSingle or Multiple Year Dilemma as Transfer Pricing Comparable Data
The selection of comparable data when conducting a comparability analysis on using transfer pricing is crucial and requires careful consideration. Two categories of data can be used, namely single-year data and multiple-year data, each of which has different characteristics, which one is better?
Mar 22, 2024
articleHigh Engagement: Seminar on PMK 172/2023 Draws Dozens of Companies in Suryacipta Industrial Estate
More than 20 representatives of companies in the Suryacipta Industrial Estate, participated in a seminar with the theme of the Latest Tax Provisions on Transfer Pricing in accordance with PMK 172 Tahun 2023.
Feb 29, 2024
articlePMK 172/2023 Updates Local Document Content in TP Documentation
Through Minister of Finance Regulation (PMK) No. 172/2023 on the Application of the Arm's Length Principle (PPKU), the Indonesian Government has updated the aspects that must be included in the preparation of the Local File, as part of the Transfer Pricing Documentation (TP Doc) report.
Feb 16, 2024
articlePMK 172/2023 Affirms the Obligations of Permanent Establishments on Related Party Transactions
The issuance of Minister of Finance Regulation (PMK) Number 172 of 2023 (PMK 172/2023) provides clearer guidelines for Permanent Establishments (BUT) that conduct transactions with related parties or parties that have special relationships.
Feb 1, 2024
articleConfirmation of Secondary Transfer Pricing Adjustment as Dividend
This confirmation is contained in Article 36, paragraph (6) Government Regulation (PP) Number 55 of 2022. This policy is a derivative of Article 18 paragraph (3) of the Law concerning Harmonization of Tax Regulations (HPP Law), which has not been detailed in explaining the definition of a dividend.
Feb 13, 2023
articleUnderstanding Three New Transfer Pricing Methods in Government Regulation Number 55 of 2022
How to determine the fairness of a special relationship transaction is now increasingly diverse, after the government released three new transfer pricing methods in Government Regulation (PP) Number 55 of 2022.
Jan 25, 2023
articleUnderstanding the Arm's Length Principles and the Consequences in Transfer Pricing
The Arm's Length Principle serves as guidelines for implementing the Advance Pricing Agreement (APA) and Mutual Agreement Procedure (MAP), which are closely related to the mitigation and handling of cross-jurisdictional tax disputes.
Oct 20, 2020
