Transfer Pricing Dispute Prevention

Are you tired of dealing with relentless transfer pricing disputes and uncertainty? An Advance Pricing Agreement (APA) may be the solution for you!

An APA is a written agreement made between Director-General of Taxes and the Taxpayer (Unilateral APA); or Director-General of Taxes and the Competent Authority of the Treaty Partner and the taxpayers concerned (Bilateral APA). The agreement governs the transfer pricing treatment  applied by tax authorities and taxpayers including the determination of the arm’s length price or profit in advance for upcoming five fiscal years and roll-back periods.

An APA offers certainty and predictability on transfer pricing arrangements between related parties and effectively reducing the risk of disputes with tax authorities. Nevertheless, the APA process can be time-consuming and complex.

Our specialized team has a proven track record of successfully obtaining APA’s for our clients, saving them time and money in the long run.

Our APA services include:

  • •Reviewing your current transfer pricing arrangements
  • •Identifying potential areas of dispute with tax authorities
  • •Developing a comprehensive APA application package approach
  • •Representing your business in negotiations with tax authorities
  • •Ongoing support throughout the APA process, including renewals and amendments

Related Awards

transfer pricing expert giving advise

Connect us today to learn how our  experienced team can support you in obtaining an Advance Pricing Agreement.

Our Related Content

Understanding Hostage-Taking as the Implementation of Ultimum Remedium in Tax Collection

In legal terminology, there is a principle called Ultimum Remedium, which means that criminal law should be used as a last resort in enforcing the law. This principle is also adopted in Indonesian Tax Law.

Understanding Taxation for Influencers

Through Social Network Analytics (SONETA) system, DGT can view and compare PPh and VAT data on social media. DGT also optimizes DGT Enterprise search to analyze taxpayers, such as family members, assets to company ownership.

Things to Consider Before Filing a Tax Dispute Resolution

Currently, Indonesia still implements a self-assessment tax collection system, which gives taxpayers the authority and trust to calculate, pay, and report their own tax obligations.

Meet the experts

Senior Advisor
fajar@taxprime.net
Senior Advisor
wawan@taxprime.net
Senior Advisor
dewo@taxprime.net
Partner
chalik@taxprime.net
Partner
abdurahman@taxprime.net
Partner
saut@taxprime.net

More Services

How Can We Assist You?

Log In

Forgot password?

Forgot password?

Enter your account data and we will send you a link to reset your password.

Your password reset link appears to be invalid or expired.

Log in

Privacy Policy

Add to Collection

No Collections

Here you'll find all collections you've created before.

×