Transfer pricing issues of a multinational enterprise may cover various aspects such as global tax planning, transfer pricing documentation, defending your merit in transfer pricing cases before the tax authorities or the tax court, responding to the demand of corresponding adjustments from other tax authorities, etc. All these aspects have become more and more important in Indonesia given the explicit requirement to maintain transfer pricing documentation and to disclose transfer pricing-related issues in the 2009 corporate income tax returns. The transfer pricing documentation requirement also applies to national enterprises engaged in domestic related party transactions, i.e. transactions with other domestic associated companies. Depending on your need, SSP CONSULTANT will assist you with the following measures that you may need to take in response to a transfer pricing issue: Reviewing the appropriateness of your global tax planning in light of the Indonesian tax legislation taking into account the tax treaty in force and international standards (OECD Transfer Pricing Guidelines). Preparing or reviewing transfer pricing documentation pertaining to controlled transactions involving Indonesian entities. Defending your company’s merit in transfer pricing-related controversies against the ITO in a tax audit, a tax objection, or a litigation before the tax court. Representing or assisting you in dealing with the ITO, if required, in the event of mutual assistance agreement (MAP).
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