A Critical Analysis of Indonesia’s New Controlled Foreign Company Rules

This article reviews Indonesia’s new controlled foreign company regulation. It explains the ways that the regulation conforms with the recommendations in the OECD’s final report on BEPS Action 3, and contrasts various aspects of Indonesia’s approach with that of Australia and the United States. Drawing on these sources, the authors suggest amendments to the Indonesian regulation to make it more effective in achieving the goal of combatting base erosion and profit shifting by Indonesian-resident corporate taxpayers.