TRANSFER

PRICING
SERVICES
MOORES ROWLAND, ID

WWW.MOORES-ROWLAND.COM
 Rules and methods for pricing transactions within and
between enterprises under common ownership.
WHAT IS Transactions between related parties must be consistent
with the arm’s length principle that proved by proper
TRANSFER PRICING transfer pricing documentation.
MoF released PMK-213/PMK.03/2016 to requires taxpayers
under certain criteria to prepare transfer pricing
documentation.

D O C U M E N T S T R A N S F E R P R I C I N G

Master File Local File Country by Country

Report (CbCR)

Who is liable to prepare

Taxpayer performs affiliated
transactions
Gross revenue more than IDR
50 billion
Tangible affiliated transactions
more than IDR 20 billion
Service, Interest, Intangible
transactions or other (each)
more than IDR 5 billion
Affiliated transactions with
other country with tax rate less
than 25%
Taxpayer performs affiliated
transactions
Gross revenue more than IDR
50 billion
Tangible affiliated transactions
more than IDR 20 billion
Service, Interest, Intangible
transactions or other (each)
more than IDR 5 billion
Affiliated transactions with
other country with tax rate less
than 25%
Taxpayer as subsidiary of
overseas UPE
UPE’s country doesn’t require
CbCR
UPE’s country hasn’t MCAA
with Indonesia
UPE’s country hasn’t MCAA
with Indonesia and CbCR can’t
be obtained
UPE : Ultimate Parent Entity
MCAA : Multilateral Competent Authorities

The Moment of Truth

Moores Rowland has grown to become one of Indonesia’s leading financial
services and advisory firms in Jakarta and Bali.
Our transfer pricing team meet and work together frequently to a common
standard, so you can be confident of consistency and good communication,
key areas in the arena of International Taxation.

CONTACT
021-720-2605
www.moores-rowland.com
contact-jakarta@moores-rowland.com
085959702972
christian.emerson@moores-rowland.com

MOORES ROWLAND INDONESIA

Jakarta - Bali