#Transfer Pricing Guidelines

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

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

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

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

UN Solutions for Optimizing Transfer Pricing Compliance

Amid increasingly complex global business processes influenced by international supply chains and technological developments, compliance with transfer pricing regulations is key for developing countries to prevent potential revenue leakage.

Oct 7, 2024

OECD 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

An Overview of Approaches in Preparing Transfer Pricing Documentation

Aug 1, 2024

Reviewing 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

Single or Multiple Year Dilemma as Transfer Pricing Comparable Data

The selection of comparable data when conducting a comparability analysis on using transfer pricing is crucial and requires careful consideration. Two categories of data can be used, namely single-year data and multiple-year data, each of which has different characteristics, which one is better?

Mar 22, 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 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

Preventing 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