The Ministry of Finance Republic of Indonesia (“MoF”) has issued Regulation No. 213/PMK.03/2016 (“PMK 213”) dated 30 December 2016 which applicable for tax year ended on or after 30 December 2016. PMK-213 adopts the three – tiered approach of the transfer pricing documentation in line with the recommendations of the BEPS Action 13 OECD TP Guidelines :
- Master file (MF);
- Local file or Transfer Pricing Documentation (LF) ; and
- Country-by-Country Report (“CbCR”)
Not only Multi National Company is mandatory to prepare the Transfer Pricing Documentation (MF & LF), local company also required to prepare the Transfer Pricing Documentation, please kindly contact us for detail info regarding Transfer Pricing.
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