MAP Process

Formal Review

• After reviewing (i) the fulfilment of requirement as set forth above, and (ii) the adherence of material requested for MAP with material eligible for MAP request, the Director General of Taxes determines whether the said MAP request is admissible.
• In respect of the MAP request from the Applicant, the Director General of Taxes will issue: 

1. written notification to the Applicant that MAP request is admissible and written request to the Competent Authority of the Tax Treaty Partner, in case the MAP request fulfils the formal requirement and material adherence; or
2. rejection letter to the Applicant describing the ground for such rejection, in case the MAP request doesn't meet the formal requirement and/or the material adherence within one month since the acceptance of the MAP request.

• In respect of the MAP request from the Competent Authority the Tax Treaty Partner, Director General of Taxes will issue:

1. written notification to the Competent Authority of treaty partner and the related Indonesian Taxpayer that MAP request is admissible, in case the MAP request fulfils the formal requirement (for instance, the requirement to submit MAP request within the timeframe set out in the pertinent tax treaty); or
2. rejection letter describing the ground thereof, in case the MAP request doesn't fulfil the formal requirement (for instance, the inability to meet the requirement to submit MAP request within the timeframe set out in the pertinent tax treaty) within one month since the acceptance of the MAP request.

• In case when the one-month time frame has exceeded and the Director General of Taxes has not issued any written notification, the said MAP request is deemed admissible.
• In respect of the MAP request initiated by the Director-General of Taxes, the Director General of Taxes will issue: a. written MAP request to the Competent Authority of the treaty partner; and b. written notification to the related Indonesian Taxpayer.
• In the case where the MAP request to the Competent Authority of treaty partner is not responded by the Competent Authority of treaty partner within the time frame of 8 (eight) months since the date of such request, Director General of Taxes will issue written notification to:

1. the Applicant that the MAP request is unable to follow-up; and
2. the Competent Authority of the Tax Treaty Partner that MAP request is withdrawn.