Tag
#Secondary Adjustment
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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
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
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
articleSecondary Adjustment, New Uncertainty, and Double Taxation Potential
Taxpayers are faced with new uncertainty and double taxation potential following the implementation of secondary adjustments related to transfer pricing between affiliated parties.
Sep 1, 2022
