Tag
#Corresponding Adjustment
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articleIBFD Journal Features Insight from MUC Professional on Corresponding Adjustments in Indonesia
MUC Consulting’s Transfer Pricing Manager, Meiliana, reviews the implementation of domestic corresponding adjustments in Indonesia through an article published in the international IBFD journal. The study highlights the challenges of BEPS Action 13 and the potential for double taxation in domestic related-party transactions.
Oct 7, 2025
articleSimultaneous Tax Examination: An Alternative to Prevent Double Taxation in Transfer Pricing Disputes
In cross-border transfer pricing disputes, Simultaneous Tax Examination (STE) serves as an important alternative to prevent double taxation. Learn how STE, as outlined in PER-10/PJ/2025, offers a more collaborative solution compared to the traditionally less effective Mutual Agreement Procedure (MAP).
Jun 27, 2025
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
articlePMK 172/2023: Secondary Adjustment of Transfer Price can be Cancelled
Minister of Finance Regulation (MoF Regulation) Number 172 of 2023 released and effective on 29 December 2023, allows the tax authority to cancel the determination of secondary adjustment on transfer pricing correction.
Feb 12, 2024
articleCorresponding Adjustment, Anti Double Taxation that the Authority Ignored
Although it has been established as one of the procedures for testing transfer pricing transactions of affiliated companies in our regulations, the tax authorities have not yet utilized the corresponding adjustments. In fact, if the procedure was carried out, the corresponding adjustment can prevent double taxation due to further testing of transfer pricing transactions.
May 29, 2023
