This web page is dedicated to provide a clear and comprehensive guidance regarding Advance Pricing Agreement (APA) and Mutual Agreement Procedure in Indonesia as our commitment to implement OECD/G20 BEPS Action 14: Making Dispute Resolution More Effective.

If you wish to proceed to the Guidance on APA, please click this link: Advance Pricing Agreement. Or, if you wish to proceed to the Guidance on MAP, please click this link: Mutual Agreement Procedure.


Advance Pricing Agreement (APA)


Introduction

Directorate General of Taxes (DGT) has run an Advance Pricing Agreement (APA) Program since 2010 to assist businesses in determining the most appropriate methodology to derive the arm’s length outcome for complex transfer pricing issues and prevent disputes arising that may otherwise result in a Mutual Agreement Procedure (MAP) being necessary later.

This APA Guidance is expected as general guidance for taxpayer intended to enter into the APA program, and accordingly should be read in conjunction with Minister of Finance Regulation No.7/PMK.03/2015 concerning The Procedures for Advance Pricing Agreement.

Definition of APA

1. An advance pricing agreement (APA) is a written agreement made by and between:

  1. Director General of Taxes and Taxpayer; or
  2. Director General of Taxes and Tax Authority of Treaty Partner Country or Treaty Partner Jurisdiction which involves Taxpayer
as referred to in Article 18 Paragraph (3a) Income Tax Law of 1984 and its amendments thereto in order to agree upon the criteria and/or determine arm’s length price or arm’s length profit in advance.

The aim of APA

2. DGT has found that where there is considerable difficulty or doubt in determining the method by which the arm’s length principle should be applied, the transfer pricing issues can be more efficiently dealt with in real time as they arise rather than retrospectively years later when, for example, key personnel in the business may have moved on.

3. An APA is used to prevent disputes on transfer pricing issues.

4. The potential scope of an APA is flexible. It may relate to all the transfer pricing issues of the business or be limited to one or more specific transactions.

5. The APA legislation doesn’t provide for a determination that a permanent establishment (PE) does or doesn’t exist.

6. DGT does not levy any charge on the business for their assistance during the APA program. All services provided by DGT during APA process are free of charge.

Unilateral, bilateral or multilateral agreement

7. A binding agreement between an Indonesian taxpayer and DGT in accordance with Article 3 Paragraph (1) a MoF Regulation No.7/PMK.03/2015, is referred to as a “unilateral APA”. Although this agreement confirms the tax treatment in Indonesia, it doesn’t determine how the issues are to be resolved in any other country involved. Consequently, it doesn’t normally eliminate the risk of double taxation in relation to the transfer pricing issues it addresses. In order to achieve that comprehensively in the case of cross-border transfer pricing issues, where a Double Taxation Agreement (DTA) exists between Indonesia and the other country containing a MAP article, DGT, in accordance with Article 3 Paragraph (1) b MoF Regulation No.7/PMK.03/2015, would have to reach agreement also with the administration of the other country: this is referred to as a ‘bilateral APA’,

8. Businesses operating in several countries may wish to seek APAs that involve all the relevant administrations affected by the transfer pricing issues. Taxpayers may apply for multilateral APAs by requesting for multiple bilateral APAs. Indonesian CA will immediately follow up such requests by contacting the CA of treaty partners.

9. An Indonesian taxpayer may request for bilateral APA and unilateral APA for the same period yet different transaction. In that case, the application shall be submitted separately. For instance, the taxpayer has three related party transactions, i.e. sale of goods, purchase of raw materials and royalty payment. The taxpayer may, in this case, apply for unilateral APA for the sale of goods and purchase of raw materials, while at the same time apply for bilateral APA for the royalty payment.

10. The choice between unilateral APA and bilateral APA depends on taxpayer’s preference taking into account the availability of APA program in the treaty partner’s domestic legislation.

APAs - who may apply

11. An APA may be requested by any:

  • Indonesian resident taxpayer to DGT; or
  • Resident taxpayer from Partner Country or Partner Jurisdiction to the relevant APA unit in the said Country or Jurisdiction.

12. Every APA request will be considered on the basis of its particular facts and features, but generally DGT will be looking at the following factors taken together, whether:

  • the transfer pricing methodology proposed best achieves consistency with the transfer pricing rules and guidelines;
  • the cross border conditions between entities (actual conditions) that are the subject of the proposed APA have already been entered into and the actual conditions are unlikely to change significantly in the period of the APA;
  • the transfer pricing issues are uncertainty as to how the transfer pricing rules apply.

13. APAs won’t be declined solely by reference to the size of the transactions giving rise to the transfer pricing issues, because DGT recognizes that transfer pricing issues can be encountered by smaller businesses as well as by large multinationals.

14. When an Indonesian taxpayer business does obtain an APA, and the provision in question is made or imposed with a related Indonesian taxpayer, DGT may seek to avoid such issues by encouraging the business to apply the transfer pricing methodology as agreed in APA for the commercial purposes.

The initial contact - the Prelodgement process

15. The APA process is initiated by the taxpayer, but DGT always strongly recommends that taxpayer interested in applying for an APA contacts us first to informally discuss its plans before presenting a formal application. This is the prelodgement stage. Prelodgement is conducted to ensure that the resources of the business aren’t wasted, on an unsuitable application, and to ensure that the detailed work that will need to be undertaken by the business in finalising its application is focused on relevant issues. It is also to build the cooperative relationship essential to the entire APA process in order to reach mutually agreed outcomes. In building this type of relationship, it is necessary to align taxpayer and DGT expectations as much as possible by outlining a realistic anticipated timetable for agreeing an APA based on past experience, or to discuss other practical issues with the business.

16. The contact details for prelodgement in an APA and for making an APA application could be found in part Indonesian CA Contacts below. Taxpayer should also make their Account Representative aware of their interest in an APA and send them a copy of the correspondence.

17. Taxpayer who submits prelodgement request shall submit a written agreement to provide all required documents in APA application process and it shall be supplemented with supporting documents as follows:

  • explanation from taxpayer regarding the reason(s) of APA application;
  • explanation regarding taxpayer's activities and business;
  • explanation regarding taxpayer's business plan;
  • business structure which covers group business structure, ownership structure and organization structure;
  • explanation regarding shareholders and explanation regarding transaction made by shareholders with the taxpayer;
  • explanation regarding the affiliated parties and detailed explanation regarding transaction made by those affiliated parties with taxpayer;
  • explanation regarding transaction with related parties for the last 3 (three) tax years if there is any;
  • explanation on transactions proposed to be discussed and covered in APA and the explanation regarding those transactions;
  • transfer pricing method and explanation regarding comparability analysis, functional analysis, selection and designation of comparable and selection of transfer pricing method;
  • explanation regarding situation or circumstances in taxpayer's activity or business whose change may have material influence on taxpayer's transfer pricing method;
  • explanation regarding accounting system, production process and decision making process;
  • explanation regarding competitors who have same or similar type of activity or business or product with taxpayer, including explanation regarding competitor's characteristic and market share;
  • copy of taxpayer's deed of establishment and its amendments or alike;
  • copy of taxpayer's Income Tax Return and annual report for the last 3 (three) years; and

18. Prelodgement shall generally cover the discussion on:

  • The necessity of APA;
  • The scope of APA proposed by taxpayer;
  • The proposed transfer pricing method;
  • Possibility of APA formation which may include treaty partner;
  • Documentation and analysis made by taxpayer;
  • The length of time and tax year period which shall be covered in APA; and
  • Other relevant matters to APA formation and implementation

19. DGT’s experience is that discussion of these issues at a meeting is much speedier and more productive than correspondence. DGT is usually able to indicate at the conclusion of a prelodgement whether it will be prepared to consider an application for an APA. Provision of details of the proposed covered transactions, and any slide presentation intended to be given to DGT beforehand, will help make the prelodgement meeting as productive and informative as possible.

20. A prelodgement can best be evaluated where the identity of the business is known as DGT can’t make any commitment over acceptance into the APA until the identity of the business is known.

21. In the event that DGT considers that an application shouldn’t be admitted into the APA, DGT will advise the taxpayer of the reasons why DGT takes that view. However, there is no right of admission as Prelodgement shall not bind DGT or the taxpayer to form APA.

Term of the agreement and ‘Roll-Back’

22. An APA will be operative for a specified period from the date of entry into force as set out in the agreement. The taxpayer should propose a term for the APA, taking into account the period over which it is reasonable to assume that the method for dealing with the relevant transfer pricing issues will remain appropriate. APA period can be granted for a maximum of 3 (three) tax years for unilateral APA, or for a maximum of 4 (four) tax years for bilateral APA.

23. An APA is intended to cover periods in advance of those where a return is already made at the date of application. However, it is possible that a fiscal year in APA period may have ended before agreement is reached. In that case, DGT may allow the APA to be effective for that year, and the agreement may set out any adjustments to be made for tax purposes as a consequence of the agreement.

24. The agreed transfer pricing methodology may be relevant for an earlier period (“Roll-back”), and to the resolution of any transfer pricing enquiries raised for earlier periods, if the particular facts and circumstances surrounding those years are substantially the same. Consequently, in such circumstances, the taxpayer may wish to consider requesting that the bilateral APA also covers this earlier period and is used as a basis for amending their self-assessment return for those years. The roll-back will be implemented via MAP, but this possibility is dependent on the ability and willingness of both administrations to roll-back.

25. Except where roll-back is being considered, the request for an APA in respect of future years won’t in itself affect any transfer pricing adjustment into earlier years. However, to the extent such an approach is appropriate and feasible, DGT will co-ordinate the APA request in respect of future years with any transfer pricing audit in respect of prior years in order to improve overall efficiency and reduce duplication of enquiries.

The formal APA application

26. Where, following DGT’s notification that it considers that prelodgement can be followed up to APA discussion stage and the taxpayer wishes to proceed, the taxpayer should submit a formal written application at the date not later than the end of tax year prior to the tax year covered in APA, or at a date explicitly agreed at the prelodgement. It is also encouraged that APA application be copied and sent to the tax office where taxpayer is registered.

27. The documents and information that should be incorporated in the formal application, are:

  • detailed explanation about the prelodgement results held previously between Director General of Taxes and Taxpayer;
  • detailed explanation about proposed Transfer Pricing method from taxpayer, including documentation which has been made by taxpayer;
  • detailed explanation about circumstances which may influence transfer pricing method;
  • detailed explanation and documentation which shall show that the implementation of transfer pricing method proposed by taxpayer has met arm’s length principle; and
  • detailed explanation about critical assumptions analysis; and
  • other required supporting documents.

28. In the case of a bilateral APA the taxpayer will be expected to ensure that all information provided in the application to one administration is made available at the same time to the other administration involved.

29. APA information is subject to the rules of confidentiality as stipulated under Article 34 of Law on General Provisions and Tax Procedures (Law No. 6 Year 1983). Information exchanged with treaty partners - for instance, in the course of reaching agreement on bilateral APAs - is also protected from disclosure by the terms of the Exchange of Information Article in the relevant DTA. Further, any information obtained during the APA process will not be used for tax audit purposes.

APA Discussion Stage

30. On receipt of an application DGT will evaluate its contents and will seek clarification and further information from the business as necessary. The examination of the application should be a co-operative process in which the transfer pricing issues are discussed openly and access to relevant supporting information and documentation is made available. Lack of co-operation in these respects may result in DGT declining to give any further consideration to the application.

31. Where a bilateral APA is being sought, DGT will expect the business to continue to make relevant information available at the same time to each administration involved, and in turn DGT will keep the treaty partner informed about the progress of its examination of the APA request, will seek to discuss with the treaty partner key issues arising at the earliest opportunity and will keep the business informed about the progress of the bilateral process.

32. Taxpayer will not attend the BAPA negotiation, unless both CAs mutually consent to allow the taxpayer to be present during the negotiation in order to explain the issues under discussion. Accordingly, finalising a bilateral agreement with a treaty partner is a government-to-government process.

Reaching agreement

33. The agreement between DGT and the taxpayer will be made subject to its terms being observed. The terms will include:>br>

  • a commitment from the taxpayer to demonstrate compliance to the agreed method for dealing with the transfer pricing issues during the term of the APA in the form of annual compliance report as required by Article 20 Paragraph (3) Minister of Finance Regulation No. 7/PMK.03/2015.
  • the identification of Critical Assumptions bearing materially on the reliability of the method and which, if subject to change, may render the agreement invalid.

34. The person responsible for signing the agreement on behalf of the taxpayer would be the person responsible for signing a tax return, subject to that person having authority to commit the taxpayer to the terms of the APA.

35. DGT endeavors to complete the APA discussion within 12 months from the acceptance of formal APA request, or in the case of bilateral APA, within the timeline stipulated in MAP regulation. This objective is dependent on the complexity of the case and, in the case of bilateral or multilateral applications, may be dependent on the working practice of the administration(s) in the other country or countries. It is also, of course, dependent on co-operation from the applicant. DGT may view significant delay on the part of the taxpayer as indicative of a lack of co-operation or a loss of interest in agreeing an APA and may then terminate the APA process as a result.

36. DGT expects the taxpayer to facilitate an efficient process by providing all the information necessary to consider the application properly and reach agreement in timely manner. This extends to the enterprise’s co-operation in ensuring that the formal APA agreement and any associated procedural paperwork are finalised shortly after the finalisation of the transfer pricing method and/or, in a bilateral or multilateral process, the concluding of agreements with treaty partner(s).

37. The tax administrations can’t give effect to, and the taxpayer can’t rely upon, the MAP APA reached between the Competent Authorities on its case unless, and until, the issuance of Director General of Taxes Decree stating the implementation of APA/MAP.

38. If agreement on the terms of an APA can’t be reached with the taxpayer, DGT will issue a formal letter to notify such disagreement. DGT doesn’t consider it has any obligation to continue discussion beyond the point at which it has determined that agreement can’t be reached.

39. DGT, and generally its treaty partners, will expect the actual pricing of the transactions covered by an APA to be consistent with the transfer pricing methodology and terms defined within it. Adjustments arising within the tax computation are expected to also be made in the accounts, thereby ensuring the economic and tax position of the arm’s length price is aligned.

APA monitoring and review - annual reports

40. The annual compliance report will generally accompany the business’s tax return, which is not later than 4 (four) months after the end of tax year. The report should be sent to the DGT office responsible for monitoring the APA, which is Directorate of International Taxation. Taxpayer may send the digital copy of annual compliance report to the email address: map@pajak.go.id. A copy may be sent to the Account Representative.

41. The requirements of each report will consist of

  • detailed explanation on Taxpayer compliance in implementing Transfer Pricing method on transactions covered in APA;
  • detailed explanation on the accuracy and consistency of the implementation of Transfer Pricing method;
  • detailed explanation on the accuracy of factors which may influence critical assumptions on the implementation of Transfer Pricing method;
  • detailed explanation that the tax return is in accordance with the APA; and
  • other information which supports explanation above.

42. The broad intention is that Annual Reports should demonstrate whether the business has complied with the terms and conditions of the APA.

APA Cancellation and Review

43. In accordance with Article 20 and 21 of Minister of Finance Regulation No. 7/PMK.03/2015, an APA may be reviewed or cancelled by DGT in accordance with its terms, where:

  • taxpayer does not comply with APA;
  • taxpayer submitted false data/information;
  • taxpayer does not submit annual compliance report in accordance with the provisions in Article 20 Paragraph (1) and Paragraph (2) MoF 7/PMK.03/2015;
  • taxpayer submits annual compliance report but does not fulfil the requirements as referred to in Article 20 Paragraph (3) MoF 7/PMK.03/2015;
  • there exist some changes in factors influencing critical assumption;
  • there is evidence that APA contains error; or
  • taxpayer is accused of tax crime.

44. In practice, when considering reviewing or cancelling the APA, DGT will consult with the taxpayer and with the Competent Authority of the treaty partner involved. Where a date of cancellation of the APA needs to be determined, it will be determined by the nature of the event that led to the cancellation.

Revising and renewing APAs

45. In some cases the APA may provide for revision of its terms in specific circumstances; for example, a particular agreement may provide that where there has been a change which makes the agreed methodology difficult to apply, but which doesn’t go as far as to invalidate a critical assumption, the agreement may be modified with the consent of the parties to resolve that difficulty. In such cases the APA may be revised in accordance with Article 21 of MoF 7/PMK.03/2015 after consultations between the taxpayer and DGT and, in the case of bilateral agreements, the Competent Authority of the other country involved.

46. The taxpayer may request renewal of an APA for an additional fixed period no later than 6 months preceding the expiry of its current term. Renewal will be processed similarly to ‘regular’ APA request, but the process should be lighter since DGT has already obtained the substantial information from previous APA as long as there is no substantial changes on facts and circumstances. DGT will consider interest in a renewal in light of current international thinking and DGT’s practice at the time. It will also consider whether the previous APA methodology and its monitoring requirements for all parties have functioned as well as intended.

 

Mutual Agreement Procedure (MAP)


Introduction

1. This MAP Guidance describes the Indonesia’s practice in relation to procedures for reducing or preventing double taxation.
Indonesia has made efforts to strengthen the efficiency and effectiveness of the dispute resolution process and minimise incidences of unintended double taxation in light of recent experience and developments, in particular Action 14 “Making Dispute Resolution more Effective” (the Action 14 Report) of the Base Erosion Profit Shifting (BEPS) project. Indonesia has committed to implementing the minimum standard in respect of:

  • preventing disputes
  • availability and access to MAP
  • resolution of MAP cases
  • implementation of MAP agreements

2. The MAP Guidance outlines the MAP process and the use of MAP under the relevant Indonesia Double Taxation Agreements.

3. This MAP Guidance should be read in conjunction with Minister of Finance Regulation No.240/PMK.03/2014 concerning The Implementation Guidelines of Mutual Agreement Procedure.

Definition of MAP

4. Mutual Agreement Procedure, hereinafter referred to as “MAP”, is an administrative procedure which is stipulated in the Tax Treaty to resolve issues arising from the application of Tax Treaty, including transfer pricing issues.

The aim of MAP

5. A MAP request can be made when a person considers that the actions of one of both countries’ tax administrations result or will result in taxation not in accordance with the relevant tax treaty. The person may request Competent Authority (CA) assistance under the MAP.
The treaties require that the taxpayer presents his case to the CA of which he is a resident or, if his case comes under non-discrimination provisions, to that of the CA of which he is a national.

Eligibility for MAP

Acceptance into MAP

6. MAP can be requested in parallel with:

  • Request of Objection as referred to in Article 25 of Law on General Provisions and Tax Procedures (Law No. 6 Year 1983);
  • Request of Appeal as referred to in Article 27 of Law on General Provisions and Tax Procedures (Law No. 6 Year 1983); or
  • Request of Deduction or Cancellation of Incorrect Notice of Tax Assessment as referred to in Article 36 Paragraph (1) Sub-paragraph b of Law on General Provisions and Tax Procedures (Law No. 6 Year 1983);
However, based on the existing regulation, MAP cannot be requested in the event that the hearing process has been finalised by the Tax Court on the Notice of Tax Assessment which is requested for MAP since the MAP outcome could not be implemented effectively.
Nonetheless, Indonesia is amending its new MAP regulation to enable the admission of taxpayer’s MAP request even when Tax Court has finalized the hearing process on the Notice of Tax Assessment.

Rejection of MAP requests

7. In cases where it appears to the Indonesian CA that the taxpayer’s MAP request may be inadmissible or not justified, Indonesian CA will write to the other CA setting out the reasons why Indonesian CA believes the request is invalid and invite the other CA to provide its views before deciding to reject the request.

The MAP process

How to make a MAP request

8. Indonesian CA requires that sufficient information and documentation is provided to fully assess the request for MAP. A detailed list of the information and documentation requirements are as follows:

  1. name, Taxpayer Identification Number, address, and type of business of Indonesian Taxpayer which requests MAP
  2. name and identity of resident Taxpayer of Treaty Partner Country or of Treaty Partner Jurisdiction related to Transfer Pricing transaction, among other things, identity number of Taxpayer and certificate of domicile;
  3. name and identity of Taxpayer of Treaty Partner Country or of Treaty Partner Jurisdiction which performs withholding tax on incomes received or earned by Indonesian Taxpayer which files request for MAP, among other things, identity number of Taxpayer and certificate of domicile;
  4. Fiscal Year and/or Tax Period which is requested for MAP;
  5. Actions already taken by Tax Authority of Treaty Partner Country or of Treaty Partner Jurisdiction or by Taxpayer of Treaty Partner Country or of Treaty Partner Jurisdiction, which are considered not in accordance with the provisions of Tax Treaty;
  6. explanations on transaction already adjusted by Tax Authority of Treaty Partner Country or of Treaty Partner Jurisdiction, which cover substance of transaction, amount of adjustment, and the basis of the adjustment; and
  7. opinion of Indonesian Taxpayer on application of the provisions of Tax Treaty in connection with the actions of Tax Authority of Treaty Partner Country or of Treaty Partner Jurisdiction as referred to point f.

9. Aside from the requirements above, MAP request shall meet the following provisions:

  1. The request shall be written in Bahasa Indonesia;
  2. The request shall be signed by Indonesian Taxpayer or his legal representative as referred to in the Law on General Provisions and Tax Procedures (Law No. 6 Year 1983); and
  3. In the event of being signed by his representative, it shall be supplemented with special power of attorney as referred to in the Law on General Provisions and Tax Procedures (Law No. 6 Year 1983)

10. Nonetheless, despite the taxpayer request, Director General of Taxes may request for MAP on matters which are deemed necessary and at the initiative of the Director General of Taxes. The matters which are deemed necessary and at the initiative of the Director General of Taxes are furtherly explained in Article 12 of Minister of Finance Regulation No. 240/PMK.03/2014.

Time limits for submitting a MAP request

11. Taxpayer shall request for MAP within the time limit as stipulated in the Tax Treaty. Please be advised to check the pertinent Tax Treaty, since the provisions regarding time limit may vary for each Tax Treaty.

Implementing the MAP outcome

Scope for granting relief

12. In the event Indonesian CA concludes that an action has led to taxation not in accordance with the treaty (and that the MAP request is admissible and justified) then the Indonesian CA will first consider if the issue can be resolved on a unilateral basis. In this case, Indonesian CA may grant relief, under the provisions of the treaty, without the need to enter into bilateral discussion with the other tax authority.

13. In the event Indonesian CA can’t resolve the issue unilaterally, then Indonesian CA will take up the matter with the CA of treaty partner. If discussions between the CAs provide adequate evidence to satisfy the Indonesian CA that an adjustment made by the other tax authority is in accordance with the tax treaty, say for example it was required in order to comply with the arm’s length principle, the Indonesian CA will grant a corresponding adjustment.

14. In the event the CAs can establish that the primary adjustment was excessive (a non-arm’s length amount), they will agree a course whereby the primary adjustment is reduced and the remaining adjustment is relieved in an amount that reflects an arm’s length result. In case, however, the Indonesian CA remains dissatisfied, there’s no obligation on it to grant relief.

15. As part of the MAP process, where an agreement is finalised between the relevant CAs, the taxpayer is notified of the decision and is provided with an explanation of the result. Once the taxpayer has accepted the agreement, written confirmation of the agreement is exchanged between the administrations. The results are processed by the tax administrations and relief is obtained.

Methods of giving relief

16. As stipulated in the relevant Tax Treaty, any agreement reached during MAP will be implemented notwithstanding any time limits in the domestic laws.

17. Relief may be granted through recalculating the tax payable, for instance by amending the Notice of Tax Assessment; amending the Objection Decision; amending the Deduction or Cancellation of Incorrect Notice of Tax Assessment; or refunding the tax should not have been payable (in case of withholding tax).

Other matters

APA and MAP Statistics

APA Statistics

18. We provide the Indonesia APA and Statistics as shown below:

Year

Description

MAP

APA

Total

Pre-2016

Requests Received

69

14

83

Requests Closed

1

0

1

Ending Balance

68

14

82

2016

Requests Received

19

25

44

Requests Closed

32

3

35

Ending Balance

55

36

91

2017

Requests Received

16

2

18

Requests Closed

20

3

23

Ending Balance

51

35

86

2018

Requests Received

26

13

39

Requests Closed

17

15

32

Ending Balance

60

33

93


Source: Directorate of International Taxation APA and MAP Statistics

19. Aside from the above-mentioned statistics, Indonesia also provides the OECD with the MAP Statistics prepared pursuant to OECD Framework as shown below:
MAP Statistics for Year 2016

For further details of OECD MAP Statistics of Indonesia for Year 2016, you may access the following hyperlink: 2016 MAP Statistics Indonesia

 

MAP Statistics for Year 2017

For further details of OECD MAP Statistics of Indonesia for Year 2017, you may access the following hyperlink: 2017 MAP Statistics Indonesia

Indonesian CA contacts

20. Requests for more information and for access to MAP and APA should be directed to the designated Indonesian CA:
Director of International Taxation,
Directorate General of Taxes,
JI. Jenderal Gatot Subroto 40-42 Jakarta 12190
Phone +62 21 5250208, 5262880, 5251609 ext. 51110,
Fax +62 21 5732064
email: map@pajak.go.id

21. For the purpose of communication between CAs, DGT is able to conduct the communication via face to face meeting, call conference, video conference, facsimile, and email. DGT prefers to use email with encrypted attachment for exchanging information as well as position for MAP purposes. For security and confidentiality reasons, instead of mentioning the full identity of the taxpayer, please be advised to use the initial thereof. The email should be addressed to the aforementioned dedicated email: map@pajak.go.id with cc to the contact information of Indonesian CA Team as follow.

22. The contact information of Indonesian CA Team:

Name Position Region Email
P.M. John L. Hutagaol Competent Authority (Director of International Taxation) Worldwide poltak.hutagaol@pajak.go.id
Achmad Amin Deputy Director of International Taxation for Dispute Resolution Worldwide achmad.amin@pajak.go.id
Denny Christianto Section Chief for International Taxation Dispute Resolution I ASEAN Countries, Australia, New Zealand and Pacific Countries denny.christian@pajak.go.id
Edi Sihar Tambunan Section Chief for International Taxation Dispute Resolution II Japan, United States, Canada, and South American Countries edi.tambunan@pajak.go.id
Andik Kusbiantoro Section Chief for International Taxation Dispute Resolution III South Korea, China and other Asian Countries (Non-ASEAN) andik.kusbiantoro@pajak.go.id
Ivan Sandy Section Chief for International Taxation Dispute Resolution IV European Countries and African Countries ivan.sandyst@pajak.go.id

Legal Basis

23. The English version of our legal basis regarding MAP and/or APA could be accessed through the following link: