PMK 172 Tahun 2023

Law Number 7 of 1983 concerning Income Tax as last amended by the Law on Harmonization of Tax Regulations (HPP). [Article 1 item 1]

Law Number 8 of 1983 concerning VAT and LGST as last amended by the HPP Law. [Article 1 item 2]

Law Number 6 of 1983 concerning General Provisions and Tax Procedures as last amended by the HPP Law. [Article 1 item 3]

The price in a transaction influenced by a special relationship. [Article 1 item 4]

Parties who have a special relationship with one another. [Article 1 item 5]

A transaction conducted by a Taxpayer with Affiliated Parties. [Article 1 item 6]

A transaction covering Affiliated Transactions and/or transactions between parties with no special relationship, but where an Affiliated Party of one or both transacting parties determines the counterparty and the transaction price. [Article 1 item 7]

A transaction conducted between parties who do not have a special relationship and which is not influenced by a special relationship. [Article 1 item 8]

The determination of price in Transactions Influenced by a Special Relationship. [Article 1 item 9]

The principle applicable in sound business practices conducted as in Independent Transactions. [Article 1 item 10]

A series of activities to collect and process data, information, and/or evidence objectively and professionally to test compliance with tax obligations. [Article 1 item 11]

Documents maintained by the Taxpayer containing data/information to support that transactions with affiliated parties are in accordance with the ALP. [Article 1 item 12]

An individual or entity, including a taxpayer, tax withholder, and tax collector having tax rights and obligations. [Article 1 item 13]

A group of tax subjects carrying out business activities consisting of parties that have a special relationship. [Article 1 item 14]

An agreement between the Government of Indonesia and the government of a partner country/jurisdiction to prevent double taxation and tax evasion. [Article 1 item 15]

A country or jurisdiction bound with the Government of Indonesia in a P3B. [Article 1 item 16]

The tax authority in the P3B Partner country authorized to implement the provisions in the P3B. [Article 1 item 17]

An administrative procedure stipulated in the P3B to resolve issues arising in the implementation of the P3B. [Article 1 item 18]

An official in Indonesia or an official in the P3B Partner country authorized to implement the MAP as stipulated in the P3B. [Article 1 item 19]

The result agreed upon in the implementation of the P3B by the Competent Authority of Indonesia and the P3B Partner regarding the MAP conducted. [Article 1 item 20]

A decision letter issued to follow up on the agreement in the Mutual Agreement. [Article 1 item 21]

An Indonesian citizen based on citizenship laws who is a domestic taxpayer of a P3B Partner. [Article 1 item 22]

A domestic Taxpayer or an Indonesian Citizen. [Article 1 item 23]

A written agreement between the Director General of Taxes and a Taxpayer or P3B Partner Tax Authority to agree on criteria and/or determine arm's length prices or profits in advance. [Article 1 item 24]

A document containing the agreement between the Director General of Taxes and a domestic Taxpayer regarding criteria and Transfer Pricing determination in advance as well as roll-back. [Article 1 item 25]

An Advance Pricing Agreement between the Director General of Taxes and a domestic Taxpayer. [Article 1 item 26]

An Advance Pricing Agreement between the Director General of Taxes and one or more Competent Authorities of P3B Partners executed based on a domestic Taxpayer's application. [Article 1 item 27]

The tax years covered as per the application or Mutual Agreement, maximum of 5 (five) tax years after the tax year the application is submitted. [Article 1 item 28]

The application of agreement results in an APA to tax years prior to the APA Period. [Article 1 item 29]

A facility for Taxpayers to exercise rights and fulfill tax obligations electronically on the Directorate General of Taxes website. [Article 1 item 30]

The Income Tax Law and the Law on Value Added Tax (VAT) and Sales Tax on Luxury Goods (LGST). [Article 2 paragraph (1)]

A state of dependency or attachment of one party with another party. [Article 2 paragraph (2)]

Share ownership or capital participation, control, or blood or marriage family relationship. [Article 2 paragraph (2)]

A state where one or more parties control the other party, or do not stand independently in running the business or carrying out activities. [Article 2 paragraph (3)]

At least 25% (twenty-five percent). [Article 2 paragraph (4)]

No, capital participation can be direct or indirect. [Article 2 paragraph (4) letter a]

Yes, a special relationship is deemed to exist. [Article 2 paragraph (4) letter a]

Yes, a relationship between two or more Taxpayers where capital is owned (min 25%) by the same party is deemed to involve a special relationship. [Article 2 paragraph (4) letter b]

A special relationship is deemed to exist if a Taxpayer has capital participation either directly or indirectly of at least 25% (twenty-five percent) in another Taxpayer. [PMK 172 Year 2023 Article 2 paragraph (4) letter a]

Indirect ownership percentage is calculated by multiplying the ownership percentage at each level of participation. (Example: Parent's ownership in Child multiplied by Child's ownership in Grandchild). [General transfer pricing practice referencing Article 2 paragraph (4)]

Yes.

Indirect capital calculation: 50% x 50% = 25%. Since the multiplication result reaches the minimum threshold of 25%, A is deemed to have a special relationship with C due to indirect capital participation. [PMK 172 Year 2023 Article 2 paragraph (4) letter a]

No.

Indirect capital calculation: 25% x 25% = 6.25%. Since 6.25% is less than the 25% threshold, there is no special relationship between A and C based on capital calculation. [PMK 172 Year 2023 Article 2 paragraph (4) letter a]

Not necessarily. You must check for Special Relationship due to Control. A special relationship is still deemed to exist if A controls C directly/indirectly through management or the use of technology, even if the share percentage is small. [PMK 172 Year 2023 Article 2 paragraph (5)]

A special relationship due to control is deemed to exist if: a. One party controls another party through management or technology; b. There are the same persons involved in managerial/operational decision-making in both parties; or c. The parties declare themselves to be in the same Business Group. [PMK 172 Year 2023 Article 2 paragraph (5)]

No, control can occur through management, technology, or decision-making, even without majority share ownership. [Article 2 paragraph (5)]

Yes, if one party controls another party directly and/or indirectly. [Article 2 paragraph (5) letter a]

Yes, two or more parties under the control of the same party directly and/or indirectly have a special relationship. [Article 2 paragraph (5) letter b]

Yes, if one party controls another party through the use of technology. [Article 2 paragraph (5) letter c]

Yes, if one party controls another party through management. [Article 2 paragraph (5) letter c]

A special relationship is deemed to exist if there is the same person directly/indirectly involved or participating in managerial or operational decision-making in two or more parties. [Article 2 paragraph (5) letter d]

Yes, if the parties are commercially or financially known or declare themselves to be in the same Business Group. [Article 2 paragraph (5) letter e]

Yes, a special relationship is deemed to exist if one party declares itself to have a special relationship with another party. [Article 2 paragraph (5) letter f]

Blood family relationships and marriage family relationships (semenda). [Article 2 paragraph (6)]

Straight line lineage and/or sideways one degree. [Article 2 paragraph (6)]

Yes, it is a blood family relationship in a straight line of one degree. [Article 2 paragraph (6)]

Yes, it is a blood family relationship sideways of one degree. [Article 2 paragraph (6)]

Family relationships arising from marriage (in-laws). [Article 2 paragraph (6)]

Yes, it is a marriage relationship (semenda) in a straight line of one degree. [Article 2 paragraph (6)]

Yes, it is a marriage relationship (semenda) sideways of one degree. [Article 2 paragraph (6)]

Not explicitly mentioned as "one degree" (grandfather to grandchild is two degrees), but other aspects of control must be considered. This article limits the family definition to "one degree". [Article 2 paragraph (6)]

No, cousins are outside the sideways lineage of one degree. [Article 2 paragraph (6)]

They must apply the Arm's Length Principle (ALP). [Article 3 paragraph (1)]

To determine the arm's length Transfer Price. [Article 3 paragraph (2)]

By comparing the conditions and price indicators of the Transaction Influenced by a Special Relationship with those of an Independent Transaction that is same or comparable. [Article 3 paragraph (3)]

In the event that the Transfer Price indicator value is equal to the comparable Independent Transaction price indicator value. [Article 3 paragraph (4)]

They can be transaction price, gross profit, or net operating profit based on absolute values or certain ratio values. [Article 3 paragraph (5)]

It must be based on actual circumstances. [Article 4 paragraph (1) letter a]

At the time of Transfer Pricing determination and/or at the time the transaction occurs. [Article 4 paragraph (1) letter b]

It must be done separately for each type of transaction (segregation). [Article 4 paragraph (2)]

If transactions are closely linked and influence each other such that separate analysis cannot be done reliably and accurately. [Article 4 paragraph (3)]

Includes identification of transaction & affiliated parties, industry analysis, transaction condition analysis, comparability

Additional stages that must be performed before the standard stages for certain types of transactions. [Article 4 paragraph (5)]

Service transactions, intangibles, loans, other financial transactions, asset transfers, business restructurings, and cost contribution agreements. [Article 4 paragraph (6)]

To identify affiliated transactions, parties involved, and the form of the special relationship. [Article 5]

Product type, market characteristics, competitors, efficiency, economic conditions, regulations, and other factors affecting performance. [Article 6 paragraph (1)]

Contractual terms, functions-assets-risks (FAR), product characteristics, economic circumstances, and business strategies. [Article 7 paragraph (1)]

No, it covers both written and unwritten terms according to actual circumstances. [Article 7 paragraph (2)]

If conditions are same/similar, or if different but do not affect price, or if accurate adjustments can be made to eliminate the impact of such differences. [Article 8 paragraph (2)]

The party in the affiliated transaction that has simpler functions, assets, and risks. [Article 8 paragraph (4)]

A transaction between an independent party and the Taxpayer itself or with the Affiliated Party counterparty. [Article 8 paragraph (6)]

If the level of comparability and reliability is the same, internal comparables are prioritized. [Article 8 paragraph (8)]

CUP, Resale Price, Cost Plus, Profit Split, TNMM, CUT, Tangible/Intangible Asset Valuation, and Business Valuation. [Article 9 paragraph (1)]

For commodity products or goods/services with same/similar characteristics to independent transactions. [Article 9 paragraph (3)]

For distributors/resellers who do not bear significant risks and do not own unique contributions. [Article 9 paragraph (4)]

For manufacturers or service providers buying raw materials from independent/affiliated parties and possessing no unique contributions. [Article 9 paragraph (5)]

If both parties own unique and valuable contributions, activities are highly integrated, and they share significant risks. [Article 9 paragraph (6)]

If one party does not own unique contributions and other transactional methods are unavailable. [Article 9 paragraph (7)]

For transfer of tangible/intangible assets, leasing, or transfer of financial assets. [Article 9 paragraph (9)]

For business restructuring, transfer of functions/assets/risks, or transfer of assets as share replacement (inbreng). [Article 9 paragraph (10)]

Yes, if reliability is equivalent, CUP or CUT methods are prioritized over others. [Article 9 paragraph (12)]

Splitting combined profit (gross or net operating) based on contribution analysis or residual analysis. [Article 10 paragraph (4) & Article 11]

A range of price indicators formed from two or more comparables. [Article 12 paragraph (6)]

Full Range (min to max) if 2 comparables. Interquartile Range (quartile 1 to 3) if 3 or more comparables. [Article 12 paragraph (6)]

The median point within the arm's length range (if the most appropriate point cannot be determined). [Article 12 paragraph (7) letter c]

Yes, provided it improves comparability. [Article 12 paragraph (3)]

Services are actually rendered, needed, provide economic benefit, not shareholder activity, not duplication, and not incidental benefit. [Article 13 paragraph (1)]

No. Examples include parent company shareholder meetings, parent reporting, or group governance. [Article 13 paragraph (2)]

Proving existence, type, value, legal & economic ownership, and DEMPE concepts (Development, Enhancement, Maintenance, Protection, Exploitation). [Article 13 paragraph (3)]

Loan is actual (substance), needed, used for 3M (Obtaining, Collecting, Maintaining income), and meets loan characteristics (maturity, creditor recognition, right to bill). [Article 13 paragraph (4)]

Borrower must be proven to have the capability to obtain loans from independent parties and capability to repay principal and interest. [Article 13 paragraph (4) letter d number 5]

Motive, purpose, economic rationale, and expected benefit. [Article 13 paragraph (5)]

Must prove economic motive, substance, expected benefit, and that it is the best option among available choices. [Article 13 paragraph (7)]

The transaction is deemed not to meet the Arm's Length Principle (ALP). [Article 14]

The PE is treated as a separate entity independent from its head office. [Article 15 paragraph (1)]

Must submit all data/information on affiliated transactions related to the PE's business. [Article 15 paragraph (2)]

They must maintain and keep documents containing data/information to support that affiliated transactions comply with the Arm's Length Principle (ALP). [Article 16 paragraph (1)]

Transfer Pricing Documentation PMK 172/2023(TP Doc). [Article 16 paragraph (2)]

Master File, Local File, and Country-by-Country Report (CbCR). [Article 16 paragraph (2)]

Gross turnover in the preceding tax year exceeding Rp50,000,000,000.00 (fifty billion rupiah). [Article 16 paragraph (3) letter a]

Affiliated transaction value in the preceding tax year exceeding Rp20,000,000,000.00 (twenty billion rupiah). [Article 16 paragraph (3) letter b number 1]

Exceeding Rp5,000,000,000.00 (five billion rupiah) for each type of transaction. [Article 16 paragraph (3) letter b number 2]

Yes, exceeding Rp5,000,000,000.00 (five billion rupiah). [Article 16 paragraph (3) letter b number 2]

Calculated for each provision of services, interest payment, utilization of intangible goods, or other affiliated transactions. [Article 16 paragraph (3) letter b number 2]

Taxpayers are still required to create Master File and Local File if the Affiliated Party is in a country with an income tax rate lower than Indonesia's income tax rate (currently 22%). [Article 16 paragraph (3) letter c]

Gross turnover and affiliated transaction values must be annualized. [Article 16 paragraph (6)]

Income received/obtained from business activities and outside business activities after deducting returns, sales reductions, and cash discounts, before deducting expenses. [Article 16 paragraph (9)]

No, Taxpayers are still required to apply ALP (Article 3) even if not required to create TP Doc. [Article 16 paragraph (7)]

Yes, required. Although the affiliated transaction value is small (below Rp20 Billion), the TP Doc obligation applies because the gross turnover of the preceding tax year (2020) exceeded Rp50,000,000,000. [Appendix Letter A Example 1 & Article 16 paragraph (3) letter a]

Not required. The obligation does not apply because the preceding year's gross turnover (2021) did not exceed Rp50 Billion AND the value of affiliated tangible goods transactions did not exceed Rp20 Billion. [Appendix Letter A Example 1 & Article 16 paragraph (3) letter b number 1]

Yes, required. Although the turnover is below Rp50 Billion, PT ABC has service/interest/royalty affiliated transactions (in this case royalty) with a value exceeding Rp5,000,000,000 in the preceding year (2022). [Appendix Letter A Example 1 & Article 16 paragraph (3) letter b number 2]

Data from Tax Year 2022 (Preceding Tax Year). The determination of obligation is based on the gross turnover value or affiliated transaction value in the one tax year prior to the year the transaction is conducted. [Appendix Letter A Example 1 & Article 16 paragraph (3)]

No. TP Doc is prepared to support the arm's length nature of affiliated transactions. If there are absolutely no affiliated transactions in the current year (2021), then there is no object to document, even if last year's turnover met the requirement. However, if there is an affiliated transaction of even Rp1, it becomes mandatory because the turnover threshold is met. [Implication from Appendix Letter A Example 1 & Article 16 paragraph (1)]

3 (three) months, which is from October 2020 to December 2020. [Appendix Letter A Example 2]

Gross turnover must be annualized with the formula: (12 months / 3 months) x Rp20,000,000,000 = Rp80,000,000,000. [Appendix Letter A Example 2 & Article 16 paragraph (6)]

Yes, required. Because the annualized turnover value exceeds the limit of Rp50,000,000,000. [Appendix Letter A Example 2 & Article 16 paragraph (3) letter a]

No later than 4 (four) months after the end of the tax year, which is April 30, 2022. [Appendix Letter A Example 2 & Article 18 paragraph (1)]

Yes. Gross turnover includes the gross amount of income from business activities and outside business activities, after deducting returns and sales reductions. [Definition of Gross Turnover Article 16 paragraph (9) implied in Appendix Letter A]

No. Turnover Rp40 Billion (< Rp50 B). Goods Rp15 Billion (< Rp20 B). Services Rp3 Billion (< Rp5 B). No threshold is exceeded. [Appendix Letter A Example 1 (Reverse Logic) & Article 16 paragraph (3)]

The gross turnover and transaction values must be converted using the exchange rate established by the Minister of Finance for tax calculation at the end of that tax year to determine if it exceeds the Rupiah threshold. [Article 16 paragraph (8)]

Yes, because the consolidated turnover exceeds the limit of Rp11,000,000,000,000 (eleven trillion rupiah). [Article 16 paragraph (4) & Reference to Appendix A Threshold for CbCR]

Yes. The annualization provision applies to gross turnover AND affiliated transaction values. Calculation: (12/3) x Rp2 Billion = Rp8 Billion. Since Rp8 Billion > Rp5 Billion (interest limit), PT DEF is required to do TP Doc PMK 172/2023. [Article 16 paragraph (6)]

Master File and Local File. [Appendix Letter A Example 1 & Article 16 paragraph (2)]

Domestic Taxpayers who are the Parent Entity of a Business Group with a certain consolidated gross turnover. [Article 16 paragraph (4)]

At least Rp11,000,000,000,000.00 (eleven trillion rupiah) in the tax year prior to the reporting year. [Article 16 paragraph (4)]

If the foreign Parent Entity is domiciled in a country that: does not require CbCR, has no information exchange agreement with Indonesia, or has an agreement but CbCR cannot be obtained (exchange failure). [Article 16 paragraph (5)]

An entity that has direct/indirect control, is required to prepare consolidated financial statements, and is not owned by another constituent entity within the group. [Article 20 paragraph (1)]

Every separate business entity that is a member of a multinational Business Group included in the consolidated financial statements. [Article 21 paragraph (1)]

Based on data and information available at the time the Affiliated Transaction occurs (ex-ante). [Article 17 paragraph (1)]

Based on data and information available up to the end of the tax year. [Article 17 paragraph (2)]

No later than 4 (four) months after the end of the tax year. [Article 18 paragraph (1)]

No later than 12 (twelve) months after the end of the tax year. [Article 18 paragraph (2)]

Yes, it must be accompanied by a statement letter regarding the availability time of the document signed by the party providing the document. [Article 18 paragraph (3)]

A summary of the Master File and Local File documents that must be submitted to the DGT. [Article 19 paragraph (1)]

As an attachment to the Corporate Income Tax Return (SPT) for the relevant tax year. [Article 19 paragraph (2)]

As an attachment to the Corporate Income Tax Return (SPT) for the following tax year (or simultaneously with notification in the 12th month). [Article 19 paragraph (3) & Article 23 paragraph (4)]

Taxpayers who are members of a Business Group must submit a notification to the DGT via the Taxpayer Portal stating the identity of the parent entity and its reporting obligations. [Article 23 paragraph (1)]

No later than 12 (twelve) months after the end of the tax year. [Article 23 paragraph (4)]

Yes, the receipt for CbCR submission can be used as a substitute for the country-by-country report in the SPT attachment. [Article 23 paragraph (6)]

Yes, CbCR working papers must be in the form of a digital copy (softcopy) with XML (extensible markup language) extension. [Article 25 paragraph (2)]

a. Ownership structure & chart; b. Business activities; c. Intangible assets; d. Financial/financing activities; e. Consolidated financial statements & tax information. [Article 29 paragraph (1)]

Yes, included in the group's business activity information. [Appendix Letter D]

Yes, an explanation of the group's strategy in development, ownership, and exploitation of intangible assets is mandatory. [Appendix Letter D]

List of shareholders, ownership percentages, and list of management for each Business Group member. [Appendix Letter D Item 1.a]

Yes, a chart showing the entire share ownership relationship and geographical location (country/jurisdiction) of each member. [Appendix Letter D Item 1.b & 1.c]

An explanation of the factors that play an important role in determining the profit of group members. [Appendix Letter D Item 2.b]

For the top 5 (five) products/services by turnover, and other products with a value of 5% or more of the group's total gross turnover. [Appendix Letter D Item 2.c]

Yes, a list and explanation of important contracts, including the capabilities of service providers and transfer pricing policies on cost allocation. [Appendix Letter D Item 2.d]

Yes, the Master File contains a general explanation of the Group's functions, assets, and risks, and the contribution of each member in value creation. [Appendix Letter D Item 2.f]

Yes, explanation regarding restructuring, acquisitions, and divestitures during the last 5 years. [Appendix Letter D Item 2.g]

Strategy for development, ownership, exploitation, location of R&D facilities, and R&D management location. [Appendix Letter D Item 3.a]

Yes, a list of intangibles important for TP analysis and the group members who legally own them. [Appendix Letter D Item 3.b]

Yes, a list of contracts between group members related to intangibles including CCAs, R&D services, and licenses. [Appendix Letter D Item 3.d]

Explanation of group financing (including with independent parties) and identification of members acting as financing centers. [Appendix Letter D Item 4.a & 4.b]

Yes, the parent entity's consolidated financial statements for the relevant tax year. [Appendix Letter D Item 5.a]

Yes, a list and explanation of APAs held by other group members and other tax provisions related to income allocation. [Appendix Letter D Item 5.b]

a. Identity & business activities of the Taxpayer; b. Information on affiliated & independent transactions; c. Application of ALP; d. Financial information; e. Non-financial events. [Article 30 paragraph (1)]

Yes, the Local File must be presented in a segmented manner according to business characterization (segmented financials). [Article 30 paragraph (3) and Appendix Letter E.4.b]

There is no specific regulation requiring the use of audited financial statements within the Local File. Unaudited financial statements may be used in cases where the Taxpayer’s financial statements audited by a public accountant are not yet available. Both Local and Master Files must be available no later than 4 months after the end of the fiscal year. [Appendix Letter E.4.a]

Types of products in the form of goods or services; Industry and Market Characteristics such as market growth, market segmentation, market cycle; technology, market Size, market prospects, supply chain and value chain; competitors and level of competition; taxpayer efficiency and locational advantage; economic conditions, such as: inflation rate, economic growth (GDP growth), interest rates, exchange rates (currency fluctuations), regulations that influence and/or determine success within the industry; and any additional external or internal variables affecting business performance in the sector. [Appendix Letter E.3.b.]

Taxpayer's management structure, organization chart, and details of affiliated parties (local & foreign) and their domicile countries. [Appendix Letter E Item 1.a]

Yes, detailed explanation of operational aspects, business strategy, and indication of involvement in business restructuring. [Appendix Letter E Item 1.b]

Yes, a description of the business environment including a list of main competitors. [Appendix Letter E Item 1.c]

Transaction scheme, pricing policy for the last 5 years, and explanation of the transaction background. [Appendix Letter E Item 2.a - 2.c]

Nominal amount per type & counterparty, counterparty country, product name, quantity, and price per unit. [Appendix Letter E Item 2.d]

Yes, copies of agreements/contracts related to significant transactions. [Appendix Letter E Item 2.e]

Product type, market characteristics, competitors, location efficiency, economic conditions, and regulations. [Appendix Letter E Item 3.b]

Explanation of contractual terms, functions-assets-risks (FAR), product characteristics, economic circumstances, and business strategies. [Appendix Letter E Item 3.c]

Characteristics of the tested transaction, search for comparables (criteria & data sources), determination of tested party, and adjustments made. [Appendix Letter E Item 3.d]

Reason for selecting the tested party and the financial ratio (PLI) used. [Appendix Letter E Item 3.d Point 3]

Yes, summary of financial statements used in TP method application, including segmented financials if having more than 1 business characterization. [Appendix Letter E Item 3.f Point 2 & Item 4.b]

Yes, there must be an explanation regarding the reason for using multiple-year analysis if required. [Appendix Letter E Item 3.f Point 3]

Financial statements audited by a public accountant. If unavailable, unaudited ones may be used. [Appendix Letter E Item 4.a]

Yes, a summary of relevant financial information from comparables and their sources. [Appendix Letter E Item 4.d]

Yes, non-financial events/occurrences/facts affecting price formation or profit levels. [Appendix Letter E Item 5]

Allocation of income, taxes paid, taxes accrued, capital, retained earnings, number of employees, and tangible assets other than cash per country/jurisdiction. [Article 31 paragraph (1) letter a]

List of Business Group members and main business activities per country/jurisdiction. [Article 31 paragraph (1) letter b]

No, such information is used only for tax avoidance risk assessment. [Article 31 paragraph (4)]

Yes, Taxpayers must prepare working papers for the country-by-country report. [Article 31 paragraph (5)]

Allocation of income, taxes paid, and business activities per country/jurisdiction. [Appendix Letter F]

Grouped in the last row by filling "NON-TAX RESIDENT". [Appendix Letter F Instruction Column 1]

Sales of inventory/property, services, royalties, interest, premiums, and other income (excluding dividends from affiliated parties). [Appendix Letter F Instruction Column 2-4]

All tax payments by group members to residents in that country or other countries (cash basis). [Appendix Letter F Instruction Column 6]

Tax accrued reported in the current year's profit and loss statement (accrual basis), excluding deferred tax. [Appendix Letter F Instruction Column 7]

Based on year-end condition or annual average, consistent between years. Independent contractors participating in operations can be reported. [Appendix Letter F Instruction Column 10]

List of business group members and main business activity types (ticked) per country. [Appendix Letter G]

R&D, Intangibles, Purchasing, Manufacturing, Sales/Distribution, Admin/Management, Services to independents, Internal financing, Financial services, Insurance, Holding, Dormant, Others. [Appendix Letter G & H Instructions]

To provide brief information or explanations facilitating understanding of info in CBC-1 and CBC-2. [Appendix Letter G - CBC-3]

A detailed document containing details per entity (not aggregated per country) serving as the basis for filling CBC-1. [Appendix Letter H]

Yes, Taxpayers must prepare the country-by-country report working paper before compiling the aggregated report. [Article 31 paragraph (5) jo. Appendix Letter H]

In the form of a digital copy (softcopy) with XML extension. [Article 25 paragraph (2)]

Indonesian language. [Article 32 paragraph (1)]

Allowed, if the Taxpayer has obtained permission from the Minister of Finance to maintain bookkeeping in a foreign language. [Article 32 paragraph (2)]

Yes, it must be accompanied by its translation in the Indonesian language. [Article 32 paragraph (3)]

Using the exchange rate established by the Minister of Finance for tax calculation at the end of the tax year. [Article 16 paragraph (8)]

The Director General of Taxes. [Article 34 paragraph (1)]

No later than 1 (one) month since the request is submitted. [Article 34 paragraph (2)]

It applies to compliance supervision and Audits. [Article 34 paragraph (2)]

The time limit follows the relevant tax laws and regulations. [Article 34 paragraph (3)]

Subject to sanctions according to laws and regulations (Article 13(2) KUP Law/fine/interest). [Article 35]

The document is not considered as a document maintained at the time of transaction (ex-ante), so the DGT may redetermine rates/prices using DGT's comparable data. [Article 36 paragraph (2) and paragraph (5)]

Subject to sanctions according to applicable tax provisions. [Article 28]

Yes, the parent entity can appoint another constituent entity (Surrogate Parent Entity) to submit CbCR. [Article 21 paragraph (2)]

The Surrogate's domicile country requires CbCR, has a QCAA agreement with Indonesia, and CbCR can be obtained by the Government of Indonesia. [Article 21 paragraph (2) letter b]

The foreign parent entity may appoint one of them to submit the CbCR. [Article 21 paragraph (4)]

Through Automatic Exchange of Information. [Article 26 paragraph (1)]

Qualifying Competent Authority Agreement, which is an agreement between competent authorities qualifying for CbCR exchange. [Article 21 paragraph (2) letter b number 2]

Domestic Taxpayers (Constituent Entities) must submit CbCR directly to DGT within 3 months after the announcement of the list of countries with exchange failure. [Article 22 paragraph (3) & (4)]

No, CbCR is received and managed specifically by the Director General of Taxes (considering its confidentiality). [Article 33]

If gross turnover and affiliated transaction values are below the thresholds in Article 16 paragraph (3), they are not required to create TP Doc (MF/LF), but are still required to apply arm's length principles. [Article 16 paragraph (7)]

Dividends are profit distribution, not business transactions, but the threshold mentions "other Affiliated Transactions". Usually, dividends are not operational TP Doc objects, but shareholder activity analysis in management fees might be relevant. Specifically, Article 16 refers to "provision of services, interest payment, utilization of intangible goods, or other Affiliated Transactions". [Article 16 paragraph (3)]

A group of tax subjects carrying out business activities consisting of parties that have a special relationship. [Article 1 item 14 - referenced in Chapter IV]

Yes, a PE is a corporate tax subject (Taxpayer) which, if meeting thresholds, must create TP Doc. [Article 16 paragraph (1) jo. Article 1 item 13]

TP Doc obligation is based on gross turnover and transaction value, not on profit/loss. If thresholds are exceeded, it is mandatory. [Article 16 paragraph (3)]

No, the Summary is only for Taxpayers required to maintain TP Doc. [Article 19 paragraph (1)]

Yes, the list of shareholders and ownership percentage of each group member is mandatory. [Appendix Letter D]

Yes, explanation and scheme/chart/diagram regarding the business chain for the top 5 products/services. [Appendix Letter D]

Yes, a description of the business environment including a list of main competitors. [Appendix Letter E]

Yes, a list and explanation of APAs held by other business group members. [Appendix Letter D]

Yes, copies of agreements/contracts related to significant transactions. [Appendix Letter E]

TP Doc documents are to support affiliated transactions. If there are absolutely no affiliated transactions, there is no object to document. However, if there are even slight affiliated transactions, the Rp 50 Billion turnover threshold is met, so it is mandatory. [Article 16 paragraph (3)]

The Taxpayer's Representative or Proxy. [Appendix Letter C]

Yes, the parent entity's consolidated financial statements. [Article 29 paragraph (1) letter e]

Sanctions refer to general tax provisions (KUP). Late SPT (due to incomplete attachment) has a specific fine, but failure to provide documents during audit can trigger official assessment (Article 36 paragraph 5). [Article 28 & 35]

Physically allowed, but substantively must be separated according to the regulated structure. [Article 16 paragraph (2)]

Yes, possession of TP Doc for the last 3 years is a requirement for APA application. [Article 56 paragraph (1) letter b - Cross Reference Chapter VIII]