New Transfer Pricing Documentation Rules: Implementation of BEPS Action 13 Recommendations

In this article, the author examines Indonesia’s newly implemented regulation on transfer pricing documentation requirements. The article explains that the regulation largely conforms with the recommendations in the OECD’s final report on BEPS Action 13, but also addresses the absence of a de minimis rule, differences with respect to the ultimate parent company filing concept and the obligation to file transfer pricing documentation placed on Indonesian parent companies in a multinational group, application of the secondary filing mechanism to Indonesian subsidiary companies, submission of transfer pricing documentation, Indonesia’s adoption of ex ante transfer pricing methodology, the compliance cost burden imposed on Indonesian businesses and challenges facing the Indonesian tax authority.