When are the TP Doc Master File and Local File Reported to the Tax Office?

Many Taxpayers often mistakenly think that the thick stack of Transfer Pricing documents (TP Doc) must be uploaded or physically submitted simultaneously with the Annual Tax Return reporting. In fact, regulations in Indonesia distinguish between obligations of "Availability", "Reporting Summary", and "Submission".

Understanding these timeline differences is very crucial so that your TP Doc is considered valid and meets formal provisions. Here are the details:

1. Deadline for Availability (Availability)

Before being reported, the document must be "available" first. Article 18 of MoF Regulation (PMK) 172/2023 affirms that TP Doc cannot be created with an overnight speeding system when there is an audit (ex-post).

Deadline

The Master File and Local File must be available no later than 4 (four) months after the end of the Tax Year.

Statement Letter

The document must be accompanied by a statement letter regarding the time of document availability signed by the party providing it.

2. Deadline for Reporting (Reporting via Summary)

At the time of submitting the Annual Tax Return, Taxpayers are not required to attach the Master File and Local File in their entirety. What is mandatory to be attached is the Summary.

• Mechanism: Taxpayers are required to create a Summary of Master File and Local File and submit it as an attachment to the Corporate Income Tax Annual Return.
• Deadline: In accordance with the deadline for submitting the Corporate Income Tax Annual Return (usually 4 months after the end of the tax year or April 30).
• Summary Content: Contains a statement of document readiness and the availability date. The date listed must be in accordance with that 4-month deadline.

3. Deadline for Submission (Submission upon Request)

When are the physical documents or complete softcopy of the Master File and Local File submitted to the Tax Office? The answer is: Only when requested.

The Director General of Taxes (DGT) has the authority to request TP Doc in the context of compliance supervision (SP2DK) or Audit. Taxpayers are required to submit the Documents no later than 1 (one) month since the request date is submitted.

Timeline Summary Table (Example Tax Year 2023)

References

Ministry of Finance of the Republic of Indonesia. (2023). Regulation of the Minister of Finance Number 172 of 2023 concerning the Application of the Principle of Fairness and Business Prevalence in Transactions Influenced by a Special Relationship.