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#OECD Transfer Pricing Guidelines
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articleSingapore Officially Adopts Amount B. What About Indonesia?
Singapore has formally adopted Amount B through its Simplified and Streamlined Approach (SSA) to simplify the pricing of related party transactions. This article discusses the pilot testing mechanism, risks of double taxation, implementation challenges, and Indonesia’s policy direction regarding Amount B.
Dec 3, 2025
articleUnderstanding 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
articleOECD and IGF Collaborate to Release Transfer Pricing Framework for Mineral Sales
The Organisation for Economic Co-operation and Development (OECD) and the Intergovernmental Forum on Mining, Minerals, Metals and Sustainable Development (IGF) released documents related to the transfer pricing framework for businesses in the mining sector.
Sep 19, 2024
articleReviewing The UEA Goverment's Transfer Pricing Guidelines
Gradually yet consistently, the government of the United Arab Emirates (UAE) continues to enrich its tax policies. In a recent development, the UAE, through the UAE Federal Tax Authority (FTA), has issued instructions for the implementation of transfer pricing regulations, targeting its taxpayers.
May 6, 2024
articleRatification Regulation on the Convention of Tax Collection Assistance to be Revised
The government will revise the provisions regarding the ratification of the Conventional on Multilateral Administrative Assistance in Tax Matter, namely Presidential Regulation (Perpres) Number 159 of 2014.
Feb 28, 2024
articlePMK 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
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
articleThree-Year Fiscal Loss Recorded, DGT Can Adjust The Transfer Price
Previously, in Law (UU) Number 7 of 2021 concerning Harmonization of Tax Regulations (HPP), this authority only applies to companies that have made commercial sales for five years. However, in Article 32 paragraph (2) letter f of Government Regulation (PP) Number 55 of 2022, this authority also applies to companies that record fiscal losses for three consecutive years.
Feb 13, 2023
articleThrough PP 55/2022, Advance Pricing Agreements Can Be Made Multilaterally
Application for Advance Pricing Agreements (APA) can now be made multilaterally. Thus, there are now three types of APA applications that apply in Indonesia. Previously, there were only two types of valid APA applications: bilateral APA application and unilateral APA application.
Feb 6, 2023
articlePreventing Tax Avoidance, PP 55/2022 Adopts New Borrowing Cost Provisions
This method will compare earnings before deducting interest, taxes, depreciation and amortization (EBITDA) or Earning Stripping Rules (ESR). This method is also known by other terms, such as Fixed Ratio, Interest-to-Profits Ratio.
Feb 1, 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
articleMeasuring the Risk of Loss and Specific Costs of Transfer Pricing During Pandemic
The Covid-19 pandemic raises risks and potential losses as well as specific costs for business actors conducting transfer pricing.
Jan 11, 2021
articleThe Impact of Government Stimulus on Corporate Related-Party Transactions
The comparability of open market transactions may be influenced by the utilization of government assistance. Especially how the parties establish their commercial or financial relations and how they price their transactions.
Jan 8, 2021
articleA Comparability Analysis, OECD Introduces the Concept of Contemporaneous Uncontrolled Transactions
Contemporaneous Uncontrolled Transactions are information relating to the selection of the same period between controlled and uncontrolled transactions in the context of current information comparables
Dec 31, 2020
