• 16 Oktober 2026 - Government Brakes Restitution Disbursements and Offers Zero Percent Tax for SOE Consolidation: Steps to Maintain the 2026 State Budget Deficit • 16 Oktober 2026 - Taxpayer Wins Fully: 100% Correction of Affiliated Service Fees Overturned Due to Strong Arm’s Length Principle Evidence • 15 Oktober 2026 - The Fate of Genset vs. Fertilizer Input VAT: A Case Study on VAT Crediting During the Pre-Operational Phase of the Palm Oil Sector • 15 Oktober 2026 - Tax Court Loss: Is Input VAT from Integrated Palm Oil Estates Not Creditable Simply Because It Produces FFB? • 15 Oktober 2026 - Battle of Evidence: Why Only a Partial Portion of Multi-Billion Rupiah VAT Correction for PT GCPI Was Granted by the Tax Court • 15 Oktober 2026 - Tax Court Upholds Crediting of Royaty VAT Even After Tax Office Nullified the Underlying Expense: WP Strategy to Win VAT-CIT Equalization Disputes • 15 Oktober 2026 - Interest Correction Annulled, Does FX Loss Follow? Unpacking the Foreign Exchange Dispute Arising from Supplier Financing • 15 Oktober 2026 - Appeal Rejected Due to One-Day Delay: The Bitter Lesson of Formal Compliance in PT YI's VAT Dispute • 15 Oktober 2026 - Taxpayer Wins Absolutely! Tax Court Cancels VAT Correction of Nearly IDR 10 Billion, Affirms Bonded Zone Status Over Goods Distribution Rules! • 15 Oktober 2026 - IDR 4 Billion VAT Correction Overturned! Tax Court's Principle of Justice Prevails Over Formal Tax Invoice Code Requirements for Bonded Zones
Indonesia Inggris Member Area

Tax Authority Defeated: Why Was the Transfer Pricing-Based Export VAT Correction for PT FI Overturned by the Tax Court?

Tax Court Appeal Decision | PPN | Fully Granted

PUT-010783.16/2023/PP/M.VB Year 2024

Taxindo Prime Consulting
Monday, June 08, 2026 | 10:19 WIB
00:00
Optimized with Google Chrome
Tax Authority Defeated: Why Was the Transfer Pricing-Based Export VAT Correction for PT FI Overturned by the Tax Court?

Export VAT Base and Secondary Adjustment Dispute

This dispute originated when the Respondent adjusted the VAT Base (DPP) for Exports of PT FI for the April 2020 tax period through a secondary adjustment mechanism. This correction was a direct consequence of a corporate income tax revenue adjustment derived from the Arm's Length Principle (ALP) testing. The Respondent applied the Transactional Net Margin Method (TNMM) with a Markup to Total Cost (MTC) indicator, comparing affiliated transaction profits with internal independent transactions to conclude that there was an under-reporting of export values.

The Core Conflict of Transfer Pricing Comparables

The core conflict lies in the disagreement over the selection of comparables in the transfer pricing analysis. The Petitioner argued that internal independent transactions were not comparable on an apple-to-apple basis due to significant differences in functional, asset, and risk profiles. The Petitioner emphasized that its role in affiliated transactions was merely that of a contract manufacturer with limited risk, unlike its fully-fledged status in independent transactions. The inaccuracy in determining comparables rendered the Respondent’s profit margin calculations regulatory invalid.

Resolution and Interlinked Disputes Principle

The Board of Judges provided a resolution by referring to the principle of interlinked disputes. Since the primary correction—the adjustment of corporate income tax revenue—had been annulled in a previous court decision, the derivative correction on the Export VAT Base lacked a solid legal foundation. The Board ruled that the Respondent failed to prove that product characteristics and functional differences were adequately adjusted, thus the correction had to be legally overturned to ensure certainty for the Taxpayer.

Analysis and Impact on Link-Case Decisions

The analysis and impact of this decision underscore the importance of consistency in handling link-case tax disputes. This ruling protects Taxpayers from automatic corrections that are not supported by strong evidence for each specific tax post. In conclusion, arm's length testing in affiliated transactions requires meticulous functional analysis before making tax adjustments, especially regarding cross-tax impacts such as VAT on export supplies.

A Comprehensive Analysis and the Tax Court Decision on This Dispute Are Available Here


October 16, 2026 • Taxindo Prime Consulting

Tax Court Appeal Decision | Annual Corporate Income Tax | Fully Granted

PUT-001999.15/2020/PP/M.IIIA Year 2022

October 15, 2026 • Taxindo Prime Consulting

Tax Court Appeal Decision | PPN | Partially Granted

PUT-001709.16/2018/PP/M.VIIIA Year 2019

October 15, 2026 • Taxindo Prime Consulting

Tax Court Appeal Decision | PPN | To Reject the Appeal/ Lawsuit

PUT-001102.16/2018/PP/M.XVA Year 2019

October 15, 2026 • Taxindo Prime Consulting

Tax Court Appeal Decision | PPN | Partially Granted

PUT-000831.162020PPM.XIA Year 2024

October 15, 2026 • Taxindo Prime Consulting

Tax Court Appeal Decision | PPN | Fully Granted

PUT-000829.16/2020/PP.MXIA Year 2024

October 15, 2026 • Taxindo Prime Consulting

Tax Court Appeal Decision | Annual Corporate Income Tax | Partially Granted

PUT-000819.152020PPM.XIA Year 2024

October 15, 2026 • Taxindo Prime Consulting

Tax Court Appeal Decision | KUP | Inadmissible

PUT-000299.16/2019/PP/HT.II Year 2019

October 15, 2026 • Taxindo Prime Consulting

Tax Court Appeal Decision | PPN | Fully Granted

PUT-000085.16/2019/PP/M.IIIA Year 2025

October 15, 2026 • Taxindo Prime Consulting

Tax Court Appeal Decision | PPN | Fully Granted

PUT-000083.16/2018/PP/M.XVA Year 2019

October 15, 2026 • Taxindo Prime Consulting

Tax Court Appeal Decision | PPN | Partially Granted

PUT-000024.16/2023/PP/M.IB Year 2025

Taxindo Prime Consulting (TPC) is a firm specializing in tax, accounting, business, and business law consulting.
Taxindo Prime Consulting (TPC) is established as a trusted strategic partner, providing comprehensive solutions in tax consulting, accounting, business development, and business law. Driven by a commitment to integrity and professionalism, TPC is dedicated to delivering more than just standard consultation; we provide education, tactical advice, and concrete solutions. Our services are meticulously designed to analyze and resolve clients' tax and business challenges with objectivity, in-depth insight, and full independence, ensuring both regulatory compliance and long-term business sustainability.
OFFICE
Mega Plaza Building 12th Floor
Jl. H.R. Rasuna Said Kav C-3 Jakarta 12940

Phone :
+62 21 521 2686
+62 817 001 3303

Email :
info@taxindo.co.id
Copyright © 2026 Taxindo Prime Consulting

All content on this website is provided solely for general informational and educational purposes. This information is not intended as a substitute for professional tax advice or consultation specific to your situation. We strongly encourage you to contact our team of consultants directly to receive appropriate guidance and advice.

Taxindo Prime Consulting
Tax and Transfer Pricing Calculator
Tax Calendar
×
Newsletter