ID|EN

APA Compliance

  • As per the PMK-172/2023, the annual compliance report is not necessarily be submitted as a separate document. The agreements contained in the APA as referred to in section (1) must be reflected in the Transfer Pricing policy of the Indonesian Taxpayer, and its implementation must be stated in the Transfer Pricing Documentations for the APA Period.
  • The transfer pricing documentation, which contains the implementation of the agreement, shall be available at the same time as the tax return, which is not later than 4 (four) months after the end of the Fiscal Year. It is advisable that Taxpayer send the digital copy to the email address: map@pajak.go.id as well as another copy for the Account Representative. The broad intention is that both the Annual Corporate Income Tax Return and the Transfer Pricing Documentation should demonstrate whether the Taxpayer has complied with the terms and conditions of the APA.