Transfer Pricing Service Indonesia
Overview
Business Hub Asia provides comprehensive transfer pricing services in Indonesia, helping multinational and local companies ensure that their intercompany transactions comply with Indonesian tax and transfer pricing rules. With increasing scrutiny from the Directorate General of Taxes (DGT), companies are required to maintain accurate transfer pricing documentation and defend their pricing policies under international standards.
Our Indonesia transfer pricing experts assist clients through advisory and documentation services that are fully aligned with OECD guidelines and Indonesian regulations (PMK-22/PMK.03/2020). By combining local tax insights with global best practices, we help businesses establish defensible transfer pricing positions, prepare compliant reports, and strengthen their governance framework to minimize audit risks.
Free ConsultationKey Features
1. Transfer Pricing Advisory
Our advisory solution helps companies evaluate and design compliant pricing models for related-party transactions.
- Transaction Mapping & Risk Identification
Review intercompany activities such as service fees, royalties, loans, and goods transfers to identify potential exposure. - Benchmark Analysis
Market comparison studies using independent data sources to justify transfer prices. - Policy Design & Implementation
Development of a group transfer pricing policy in line with Indonesia’s transfer pricing regulations and OECD guidelines. - Audit Support
Advisory support during DGT reviews or audits, including documentation strategy and data clarification.
Compliance Alignment
Periodic updates on new transfer pricing rules in Indonesia to maintain consistent reporting and documentation.
2. Transfer Pricing Documentation Services
Our team assists clients in preparing and maintaining documentation as required under Indonesian law.
- Master File Preparation
Development of group-wide documentation describing organizational structure, intangibles, and financial activities. - Local File Preparation
Preparation of Indonesia-specific documentation covering functional analysis, economic comparability, and pricing methods. - Country-by-Country Report (CbCR)
Assistance in compiling or reviewing CbCR data and disclosures. - Data Compilation & Review
Validation of financial and operational data across related entities to ensure consistency with global TP documentation.
Ongoing Maintenance
Annual updates and documentation review to align with changes in business operations or regulatory standards.
Minimum Requirements
Legal Entity
A legal entity in Indonesia (PT or PT PMA) engaged in related-party transactions (domestic or cross-border)
Documentation
Complete set of intercompany agreements and financial statements
Analysis Data
Functional and risk analysis data (e.g., roles, responsibilities, assets used)
Pricing Policy
Access to comparable data and internal pricing policy (if applicable)
Internal Liaison
Designated point of contact for tax and finance coordination
Process and Timeline
1
Initial Consultation & Scoping
Define the scope of transactions, data sources, and compliance requirements. Estimated time: 1 working day.
2
Functional & Risk Analysis
Conduct interviews and review documentation to identify roles, functions, and risks. Estimated time: 3-5 working days.
3
Benchmark Study & Policy Drafting
Conduct comparable analysis and prepare a transfer pricing policy draft. Estimated time: 5-7 working days.
4
Documentation Preparation
Develop the master file, local file, and CbCR draft as applicable. Estimated time: 5-7 working days.
5
Internal Review & Finalization
Align drafts with management input and finalize documentation. Estimated time: 2-3 working days.
6
Compliance Briefing & Submission Guidance
Provide reporting guidance and a future maintenance checklist.
*The estimated total duration for a complete transfer service is approximately 3-5 weeks, depending on the complexity and data availability.
Important Consideration
- Business Hub Asia provides advisory and compliance assistance; all formal submissions are done by the client via official tax platforms.
- Transfer pricing documentation is mandatory for companies that meet the requirements defined by the Ministry of Finance.
- Inconsistent documentation may lead to audit exposure or adjustments; periodic review is strongly recommended.
- Policy updates should be implemented group-wide to ensure consistent global compliance.
Frequently Asked Questions
What is the purpose of transfer pricing documentation?
It supports compliance with transfer pricing rules by proving that intercompany transactions are conducted at arm’s length and reflect market conditions.
Who must prepare transfer pricing documentation in Indonesia?
Entities conducting related-party transactions that meet the requirements by following PMK-22/PMK.03/2020.
What is included in transfer pricing documentation?
Typically, a Master File, Local File, and Country-by-Country Report (CbCR) are required.
Are TP reports required annually?
Yes, the transfer pricing documentation should be updated annually or whenever there is a significant change in business structure or transactions.
Can Business Hub Asia assist during a tax audit?
Yes, we provide tax audit service, helping clients respond effectively to information requests.
How long should transfer pricing documentation be retained?
Documentation should be kept for at least five years, in accordance with Indonesian tax retention requirements.
Get Expert Assistance on Transfer Pricing Compliance in Indonesia
Our experts are ready to assist you with customized solutions that ensure full compliance with Indonesia’s tax regulations. Fill out the form below to connect with our consultants and receive a free initial assessment of your company’s transfer pricing needs.
Disclaimer
The content provided on this website is published by PT. Bisnis Hub Asia (“we“, or “us“) for general informational purposes only. While every effort is made to ensure the accuracy and timeliness of the information presented, we make no representations or warranties, express or implied, as to the completeness, accuracy, reliability, suitability, or availability of any content, products, or services described on this website. Any reliance placed on such information is strictly at the user’s own risk.
We are a private, independent entity and are not affiliated with, authorized by, or acting on behalf of the Government of the Republic of Indonesia, its ministries, agencies, or any officially appointed representatives. This website does not provide, offer, or promote any official government documents or services, including but not limited to:
-
Business identification numbers (Nomor Induk Berusaha – NIB);
-
Tax refunds or rebates;
-
Stay Permit or electronic travel authorizations;
-
Passports or other immigration-related documents.
Any references to such services are provided solely for general informational purposes and should not be construed as an offer or facilitation of official services.
We are committed to ensuring the protection of your personal data in accordance with Law No. 27 of 2022 on Personal Data Protection. Any personal information collected through this website will be processed for the purposes clearly stated in our [Privacy Statement]. We do not sell or misuse personal data under any circumstances.
By accessing and using this website, you acknowledge and agree to the terms set out in this Disclaimer. You further agree to use this website and the information provided responsibly and in compliance with applicable laws and regulations.
For further information or questions regarding this Disclaimer, please contact us via the channels provided on our Contact page.
Disclaimer
The content provided on this website is published by PT. Bisnis Hub Asia (“we“, or “us“) for general informational purposes only. While every effort is made to ensure the accuracy and timeliness of the information presented, we make no representations or warranties, express or implied, as to the completeness, accuracy, reliability, suitability, or availability of any content, products, or services described on this website. Any reliance placed on such information is strictly at the user’s own risk.
We are a private, independent entity and are not affiliated with, authorized by, or acting on behalf of the Government of the Republic of Indonesia, its ministries, agencies, or any officially appointed representatives. This website does not provide, offer, or promote any official government documents or services, including but not limited to:
-
Business identification numbers (Nomor Induk Berusaha – NIB);
-
Tax refunds or rebates;
-
Visas or electronic travel authorizations (e-Visa, e-VoA);
-
Passports or other immigration-related documents.
Any references to such services are provided solely for general informational purposes and should not be construed as an offer or facilitation of official services.
We are committed to ensuring the protection of your personal data in accordance with Law No. 27 of 2022 on Personal Data Protection. Any personal information collected through this website will be processed for the purposes clearly stated in our [Privacy Statement]. We do not sell or misuse personal data under any circumstances.
By accessing and using this website, you acknowledge and agree to the terms set out in this Disclaimer. You further agree to use this website and the information provided responsibly and in compliance with applicable laws and regulations.
For further information or questions regarding this Disclaimer, please contact us via the channels provided on our Contact page.
Meet the Expert
Meet the Expert
Nurmia Dwi Agustina, S.E., MBA
President Director at Business Hub Asia
Nurmia is an experienced corporate services and regulatory compliance professional with over 15 years of experience in Southeast Asia. The co-founder of Cekindo Indonesia/Vietnam and former COO of InCorp Indonesia, she has led large teams in legal, tax, and BPO. As Director at Business Hub Asia, she leads regional service delivery, helping companies navigate complex licensing and compliance in Indonesia, Vietnam, and the Philippines.
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