#Permanent Establishment (PE)

PMK 112/2025 Strengthens DGT Authority Over Test Avoidance of Permanent Establishment Status Related to Tax Treaty 

Jan 22, 2026

Understanding Formula Apportionment, an Alternative for Taxing the Digital Economy

Formula Apportionment serves as an alternative for allocating taxing rights in the digital economy era. The OECD has proposed this method to allocate the profits of cross-border digital companies, although global consensus remains stalled.

Aug 12, 2025

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