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Comply with the Indonesian Directorate General of Taxes (DGT) regulations. Manage your PMK-213 reporting, Master/Local files, and mandatory TP Summaries with expert precision.
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The Indonesian DGT enforces one of the strictest transfer pricing regimes in Southeast Asia. Under PMK-213/PMK.03/2016, taxpayers must follow the three-tiered BEPS documentation approach if specific gross turnover or transactional thresholds are met.
A unique feature of the Indonesian system is the mandatory TP Summary (Ikhtisar), which must be attached to the annual corporate income tax return. Failure to prepare contemporaneous documentation can lead to the rejection of the TP method and significant tax adjustments.
The cornerstone regulation defining documentation requirements, thresholds, and the 4-month rule for preparation.
Harmonization of Tax Regulations strengthening the DGT's authority to audit and adjust intercompany pricing.
Consolidates rules for the implementation of the arm's length principle and dispute resolution (MAP/APA).
Required for taxpayers exceeding IDR 50 Billion turnover.
Documentation is mandatory if:
Annual gross turnover > IDR 50 Billion
Affiliated transactions > IDR 20 Billion (tangibles)
Affiliated transactions > IDR 5 Billion (services/interest/intangibles)
Documents must be available within 4 months after the end of the fiscal year.
Mandatory attachment for the Annual Tax Return (SPT).
The Ikhtisar is a condensed summary of the TP documentation. It must be signed and attached to the annual tax return filing.
Late preparation of the TP documentation is often detected through this summary, leading to potential administrative penalties and audit triggers.
Threshold for groups over IDR 11 Trillion.
Indonesian parented MNEs with consolidated revenue = IDR 11 Trillion must file a Country-by-Country Report.
Secondary filing may apply to Indonesian subsidiaries if the ultimate parent is in a jurisdiction that does not exchange information with Indonesia.
Drafting bilingual (Indonesian/English) TP reports per DGT standards.
Assistance with Form 1771-3A and the mandatory TP Summary.
Using Indonesian-specific databases to satisfy DGT auditor preferences.
Navigating Mutual Agreement Procedures for double tax relief.
Avoid the 4-month deadline trap. Ensure your contemporaneous documentation is robust and audit-ready.
Contact Indonesia TeamFor further information on transfer pricing in Indonesia, please contact:
