TAXES
LAW
9
In December 2016, Indonesia issued Regulation PMK-213,
which implements the OECD BEPS Action 13 initiative. These
TP reporting requirements may be applicable to German
groups with activities in Indonesia. It requires the preparation
of three documents regarding related party transactions:
i. A Master File (“MF”);
ii. A Local File (“LF”); and
iii. A Country by Country Reporting file (“CBCR”).
The MF and LF must be available four months after fiscal
year-end, in either Bahasa or English (English version must be
accompanied by Bahasa translation). The CBCR submission
is due within one year after fiscal year-end. A MF and LF are
mandated if a Taxpayer conducts:
1. Any related-party transactions and its gross revenue
wasabove IDR 50 billion in the previous year (in this case
2015); or
2. Related-party tangible goods transactions of more than
IDR 20 billion; or
3. Related-party non-tangible goods transactions of more
than IDR 5 billion, or Related party transactions of any
amount with a party in a jurisdiction with a lower corporate
tax rate than Indonesia (25%). A list of these jurisdictions
has been published by the Tax Authorities.
KPMG Advisory Indonesia (KAI) has been providing business
advisory services focusing on taxation and related business issues
since 1957. KAI is one of the largest practices in the country,
providing services to multinational corporations, joint ventures
and domestic companies operating in a wide range of business
sectors. Our experienced tax professionals are drawn from a wide
number of countries and backgrounds. Industry specialization,
service line expertise and international exposure, together with
continuous advanced training, equips them to work with our
clients and to be their professional tax advisors in a wide spectrum
of business matters.
A CBCR is mandated if a taxpayer:
1. Is a parent entity with consolidated group revenue
of more than IDR 11 trillion (which applies to
Indonesian group companies); or
2. Is a part of a foreign parent entity that:
i. is not required to submit a CBCR, or
ii. is in a country that does not have an information
exchange agreement with Indonesia, or
iii. if the ITO is unable to obtain a CBCR through an
information exchange agreement.
The ITO has published a list of countries that have a suitable
exchange of information arrangement. PMK 213 includes an
extensive list of information to be disclosed in the CBCR.
KPMG Advisory Indonesia
Jacob Zwaan, LL.M.(taxation)
Partner
+62 215799 5147
Corporate Taxation
New Transfer Pricing Tax
Reporting Compliance Requirements in Indonesia
KPMG Advisory Indonesia
33
rd
Floor, Wisma GKBI 28
Jl Jend Sudirman
Jakarta 10210 - Indonesia
Phone : +62 21 570 4888
Fax
: +62 21 570 5888
Website :
/
default.aspx
