#Transfer Pricing

APA Provides Up to 15 Years of Tax Certainty for Investors

The DGT states APA can provide up to 15 years of tax certainty, supporting investment and reducing transfer pricing disputes.

Jul 17, 2026

Through Public CbCR, Australia Reshapes the Face of Tax Transparency

Australia's Public CbCR makes tax data public, boosting transparency while creating new compliance and reputational risks for multinationals.

Jul 6, 2026

Through APA Assistance, MUC Consulting Promotes Tax Certainty and Minimizes Disputes

APA assistance by MUC Consulting helps taxpayers obtain tax certainty over related-party transactions and minimize transfer pricing disputes. Through the Unilateral Advance Pricing Agreement (UAPA) scheme, companies can manage tax risks, enhance voluntary compliance, and ensure consistent application of the arm’s length principle.

Apr 17, 2026

The Smile Curve and Tax Sovereignty

The Smile Curve highlights the imbalance in value creation in transfer pricing disputes and its implications for tax sovereignty. This article examines the shift from value chains to value networks, critiques the concept of value, and explores the tug-of-war over taxing rights in the digital economy. 

Apr 15, 2026

Two MUC Professionals Achieve ADIT Certification in Transfer Pricing

Two certified transfer pricing consultants of MUC have passed the Advanced Diploma in International Taxation (ADIT) examination administered by the Chartered Institute of Taxation (CIOT) in the December 2025 sitting.

Feb 19, 2026

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

Transfer Pricing Tax Audits and the Significance of R&D in Comparable Data

This article discusses the assessment of the significance of R&D in transfer pricing tax audits, the challenges related to comparable data, and the urgency of legal certainty.

Jan 2, 2026

Singapore 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

IFA Hosts 13th International Tax Seminar, Featuring Expert from MUC Consulting

IFA Indonesia is hosting its 13th Annual International Tax Seminar on 3 December 2025 in Jakarta, featuring leading international tax experts, including a professional from MUC Consulting. The event will discuss strategic issues such as transfer pricing, anti-tax-avoidance policies, and updates on global taxation developments.

Nov 28, 2025

MUC Professionals Share Insights on GMT and APA in UPN Veteran Yogyakarta Practitioner Lecture

Transfer pricing professionals from MUC Consulting were invited as guest lecturers in the Practitioner Lecture at UPN Veteran Yogyakarta, discussing risk mitigation through Advance Pricing Agreements (APA) and the implementation of the Global Minimum Tax (GMT). The material is expected to strengthen students’ understanding of international taxation issues that are becoming increasingly relevant in the professional world.

Nov 18, 2025

MUC BIJAK Vol. 7: Understanding the Concept, Impact, and Administrative Obligations of the Global Minimum Tax

The MUC BIJAK Vol. 7 webinar explores the upcoming implementation of the Global Minimum Tax (GMT) in 2025, covering its fundamental concept, implications for multinational enterprises, administrative obligations, and safe harbour provisions. Gain insights into key global tax developments with GMT experts from MUC Consulting.

Nov 14, 2025

IBFD 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

Two Consecutive Years, MUC Wins Transfer Pricing Advisory Rising Star from ITR

MUC Consulting has received the Transfer Pricing Advisory Rising Star award from ITR 2025 through Rama Ames Remonda, continuing the achievement from the previous year.

Sep 22, 2025

Four MUC Professionals Attend ITR Awards 2025 in the UK

MUC Consulting was represented by four professionals at the ITR Awards 2025 and was shortlisted for 11 nominations at the Asia-Pacific Tax Awards 2025.

Sep 18, 2025

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

Ex-Ante Approach in Transfer Pricing: A Critical Issue in Tax Audits

This article discusses the importance of consistent application of the ex-ante approach in transfer pricing analysis, in line with Regulation PMK 213/2016 and PMK 172/2023. It emphasizes that the use of post-tax year data by tax auditors risks violating the fundamental principles of the ex-ante approach, potentially leading to unfairness and legal uncertainty for taxpayers.

Jul 22, 2025

Simultaneous 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

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