#Minister of Finance Regulation No. 172/2023

Breaking Down the Transfer Pricing Implications Behind the ASDP Corruption Case

This article discusses the transfer pricing implications in the ASDP corruption case, the role of the Arm’s Length Principle (ALP) and Minister of Finance Regulation (PMK) 172/2023, and how arm’s length pricing separates business risk from criminal liability. 

Jan 15, 2026

Four Measures for Transfer Pricing Risks Mitigation in 2026 

Jan 9, 2026

Tariff Wars and Transfer Pricing Compliance Strategies

Global tariff tensions, particularly between the U.S. and China, are pushing multinational companies to develop adaptive transfer pricing strategies. Learn how transfer pricing documentation (TP Doc) has become a critical tool for mitigating tax risks amid the uncertainty of import tariff policies.

Apr 22, 2025

Understanding the Various Transfer Pricing Methods

To ensure that transfer pricing set by corporate group enterprises aligns with the Arm's Length Principle (ALP), it is essential to understand the various appropriate transfer pricing methods.

Nov 13, 2024

Dozens of Semarang Entrepreneurs Enthusiastically Attend MUC's "Taxation Update" Seminar

MUC Consulting held a Seminar entitled "MUC Taxation Update" in Semarang on Thursday (7/3). The event was attended by 30 participants who were representatives of companies in the city known as Lumpia City.

Mar 19, 2024

High 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

PMK 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

Taxation Update 2024, Analyzing Key Points of PMK 168/2023 and 172/2023

With the purpose of disseminating and providing a comprehensive understanding related to two latest tax policies, namely the Minister of Finance Regulation (PMK) Number 168 of 2023 and 172 of 2023, MUC Consulting has held a Seminar titled Taxation Update 2024.

Feb 9, 2024

PMK 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

Consolidating Transfer Pricing-Related Regulations, Check Out the Comprehensive Overview of PMK 172/2023

The Indonesian government through the Minister of Finance on 29 December 2023 stipulated a new regulation related to transfer pricing, namely Minister of Finance Regulation (PMK) Number 172 Year 2023 on the application of the arm's length principle in transactions affected by special relationships (PMK 172/2023). 

Jan 31, 2024

PMK 172/2023 Changes the Threshold Reference for Consolidated Gross Revenue Related to CbCR

Through the Minister of Finance Regulation (PMK) Number 172 of 2023, the reference for determining the threshold of the consolidated gross revenue of business groups for determining the obligation to prepare and report Country by Country Report (CbCR) is amended.

Jan 25, 2024

PMK 172/2023 Details Industry Analysis Provision on PKKU

Provisions regarding industry analysis related to the arm's length principles (PKKU) are regulated in more detail in Minister of Finance Regulation (PMK) Number 172 of 2023 which took effect on 29 December 2023.

Jan 22, 2024

Examining the Deadline of TP Doc Availability in PMK 172/2023

The enactment of Minister of Finance (PMK) Regulation No. 172 of 2023 on the Application of Arm's Length Principles (PKKU) in Transactions Affected by Special Relationships has changed the provisions related to the obligation to provide Transfer Pricing Documentation (TP Doc).

Jan 19, 2024

PMK 172/2023 Reorganizes VAT on Related-Party Transactions, DGT Authorized to Adjust Selling Price

Through Minister of Finance Regulation (PMK) Number 172 Year 2023, the Directorate General of Taxes (DGT) is now authorized to make adjustments to the selling price or replacement value, as the basis for imposing Value Added Tax (VAT), in transactions affected by special relationships.

Jan 18, 2024

PMK 172 Year 2023 Reinforces Ex-Ante Provision in Transfer Pricing Regulation

Through Minister of Finance Regulation (PMK) Number 172 of 2023, the Indonesian government emphasizes the use of the Ex-Ante approach in the preparation of the Local File and Master File, as part of the Transfer Pricing Documentation (TP Doc) report.

Jan 15, 2024

New Provisions Released, Submission of TP Doc Maximum One Month from Request

The government regulates the deadline for submitting transfer pricing documentation (TP Doc) reports, to a maximum of 1 month since requested by the Directorate General of Taxes (DGT). 

Jan 12, 2024