As of March 2024, significant updates have been made regarding transfer pricing (TP) regulations in several Asia Pacific countries. The latest Indonesian Transfer Pricing (TP) guidelines are updated under MoF 172/2023, also known as the Indonesia TP Omnibus Law. This regulation unifies and clarifies provisions from previous laws, ensuring better compliance and understanding for businesses engaged in international transactions.

Legal Basis and Documentation Requirements:

• Regulation: The TP guidelines are under MoF 172/2023, effective since 2010, adopting OECD standards.
• Member Status: Indonesia is part of the OECD/G20 Inclusive Framework on BEPS.
• Acceptance: TP policies aligned with OECD guidelines are accepted by Indonesian tax authorities.

Master File (MF) and Local File (LF) Requirements:

• Thresholds:
  • Gross revenue above IDR 50 billion.
  • Tangible goods transactions above IDR 20 billion.
  • Intangible goods transactions above IDR 5 billion.
  • Any transaction with parties in lower tax jurisdictions than Indonesia.
• Language: Documentation must be prepared in Bahasa Indonesia, with no allowance for English.
• Availability: Must be available within 4 months of the fiscal year’s end and submitted within 1 month upon request during tax audits.

Country-by-Country Reporting (CbCR):

• Submission: Required electronically through the taxpayer’s portal, aligned with the fiscal year corporate tax return.
• Penalties: Non-compliance can result in penalties of IDR 1 million, and further penalties if CbCR is not submitted upon a reprimand from the tax authorities.

Access the guides here:

Asia Pacific

Indonesia

Should you have any questions or need further assistance, feel free to contact our regional experts.

This update is based on the latest available data as of March 2024. For continuous updates, please visit WTS Global Insights .