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Transfer Pricing & Related-Party Transactions

For group companies with loans, services or sales between affiliates.

Transfer pricing documentation (Master File and Local File) and review of related-party transactions, including loans, services and royalties, under the arm's length principle (PMK 172/2023).

Deadlines to watch

4 months

Transfer pricing documentation must be available within 4 months after the tax year ends.

1 month

Deadline to hand over documentation once requested.

DER 4:1

General debt-to-equity cap for deducting borrowing costs, with sector exceptions.

What's included

  • Documentation required?

    Master File and Local File obligations depend on gross revenue, related-party transaction values and where affiliates are located. We test these criteria every year, not once.

  • A defensible arm's length test

    Functional analysis, method selection and comparables are built to hold up in an SP2DK or audit, not just to meet a format.

  • Affiliate loans and services

    Affiliate loans are tested on substance, economic benefit, debt-to-equity and interest rate. Intra-group services and royalties are tested on evidence of benefit and the charging basis.

How we work

  1. 01

    Map transactions

    All related-party transactions and their values are identified.

  2. 02

    Test obligations

    Documentation criteria and high-risk transactions are determined.

  3. 03

    Analyse

    Functional, risk, method and comparables analysis is prepared.

  4. 04

    Document

    Master File, Local File and the annual return summary are prepared.

Documents we need from you

  • Group structure and list of related parties.
  • Agreements and details of related-party transactions (goods, services, loans, royalties).
  • Financial statements and corporate annual return.

What you receive

  • Related-party transaction map and documentation obligations.
  • Master File and Local File under PMK 172/2023.
  • Affiliate loan review: substance, debt-to-equity and interest rate.

If the tax office asks about this work later

The same team that did it stays with you: SP2DK replies, audits, objections, up to a Tax Court appeal.

How we handle tax disputes

Frequently Asked Questions

Who must prepare a Master File and Local File?

Taxpayers with related-party transactions meeting certain criteria, including prior-year gross revenue above IDR 50 billion, related-party transactions above set thresholds, or transactions with affiliates in lower-tax jurisdictions.

What if related-party transactions are not arm's length?

The tax office can redetermine income and costs, including treating part of a loan as equity, and the difference can be treated as a constructive dividend.

We are a small company. Does this matter?

Full documentation may not be required, but related-party transactions must still be arm's length. Shareholder loans are the most commonly adjusted.

Remote across Indonesia, with visits when the work needs it. Areas we serve

Want to talk about Transfer Pricing & Related-Party Transactions?

Tell us what you need, the period, and the state of your documents. We reply on WhatsApp.

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