Transfer pricing: intercompany alignment of intangible propertyEY
This session will explore the transfer pricing aspects of research and development activities and the types of alignment strategies that are available to enable efficient ip structures.
Gonzalo Prudencio Crispieri, Tutor del área de Proyectos de FUNIBER, presenta el estudio "Cálculo de la Tasa de Descuento: Un factor determinante en la valoración de proyectos"
Transfer pricing: intercompany alignment of intangible propertyEY
This session will explore the transfer pricing aspects of research and development activities and the types of alignment strategies that are available to enable efficient ip structures.
Gonzalo Prudencio Crispieri, Tutor del área de Proyectos de FUNIBER, presenta el estudio "Cálculo de la Tasa de Descuento: Un factor determinante en la valoración de proyectos"
This was the informative seminar on the basic taxation principles in the Philippines. It was an hour-long speech on the basics of the Philippine Tax system presented to the students of the Mindanao State University - Iligan Institute of Technology on 12 August 2011 for the Political Science 2 Lecture Series by Vivienne Cemine.\. The document was uploaded by JR Lopez Gonzales of www.politikalon.blogspot.com.
The presentation is part of a lecture series on Management Information Systems. It is an overview of the General Ledger and Financial Reporting System (GLFRS) as part of the Accounting Information system (AIS). It also covers an assessment of the role of accounting software and Extensible Business Reporting Language (XBRL).
DOI: http://dx.doi.org/10.13140/RG.2.2.22328.47369
Updated at: https://www.researchgate.net/publication/353851801_General_Ledger_and_Financial_Reporting_System_GLFRS
Estimados colegas este libro es un gran aporte del Dr. José Javier Jiménez Cano, quien debido al proceso por el que se encuentra inmersa toda Latinoamérica decidió poner a disposición de la asociación contable en la región, un gran trabajo por el conocimiento en el área financiera-contable experiencia en el proceso acaecido en España, doctor muchas gracias.
The presentation describes the structure and contents of a tax due diligence report for an international M&A transaction. It covers the typical tax issues of a cross-border transaction as well as some additional legal matters which are connected with the tax planning.
This was the informative seminar on the basic taxation principles in the Philippines. It was an hour-long speech on the basics of the Philippine Tax system presented to the students of the Mindanao State University - Iligan Institute of Technology on 12 August 2011 for the Political Science 2 Lecture Series by Vivienne Cemine.\. The document was uploaded by JR Lopez Gonzales of www.politikalon.blogspot.com.
The presentation is part of a lecture series on Management Information Systems. It is an overview of the General Ledger and Financial Reporting System (GLFRS) as part of the Accounting Information system (AIS). It also covers an assessment of the role of accounting software and Extensible Business Reporting Language (XBRL).
DOI: http://dx.doi.org/10.13140/RG.2.2.22328.47369
Updated at: https://www.researchgate.net/publication/353851801_General_Ledger_and_Financial_Reporting_System_GLFRS
Estimados colegas este libro es un gran aporte del Dr. José Javier Jiménez Cano, quien debido al proceso por el que se encuentra inmersa toda Latinoamérica decidió poner a disposición de la asociación contable en la región, un gran trabajo por el conocimiento en el área financiera-contable experiencia en el proceso acaecido en España, doctor muchas gracias.
The presentation describes the structure and contents of a tax due diligence report for an international M&A transaction. It covers the typical tax issues of a cross-border transaction as well as some additional legal matters which are connected with the tax planning.
Pedoman teknis tata cara pemotongan, penyetoran dan pelaporan pajak penghasilan pasal 21 dan / atau pajak penghasilan pasal 26 sehubungan dengan pekerjaan, jasa, dan kegiatan orang pribadi
This is an attempt to explain the broad concept of and rationale behind Transfer Pricing Regulations. Also gives a high level view of the scheme of Indian Transfer Pricing Regulations as on date. Points out the TP controversies in India. Above all gives a well spirited guidance on dealing with TP in India.
Tata Cara Ikut Tax Amnesty untuk Pegawai atau Karyawan baik Negeri maupun Swasta dan Pengecualian Objek Amnesti Pajak, untuk Konsultasi 0812-1917-9800 (telkomsel)
Introduction to TransPrice Knowledge AllianceAkshay KENKRE
TransPrice flagged off a knowledge circle amongst its members, clients and associates; the purpose of which is to spread awareness about the transfer pricing issues in the industry; to value add by representing the issues discussed in the forum at various larger forums and ultimately provide plausible solutions.
I hereby invite the industry members who are affected by Transfer Pricing and International taxation to join the group.
Interested professionals can write to me on akshaykenkre@transprice.in
This is purely a knowledge awareness session and not a business initiative.
Thanks a lot
Akshay Kenkre
Chapter C.1 - UN TP Manual: Legal Environment for Establishing TP RegimesDVSResearchFoundatio
Key Takeaways:
Considerations in the Design
Presumptive Taxation Approaches and the Arm's Length Principle
Format of Receiving TP Information
TP Rules in National Tax Regimes
Legal Framework of TP Provisions (International & Domestic) and Practical Aspect of arriving at Arm’s Length Price (ALP), TP Documentation and Report of Accountants –Form 3CEB’
OTC Derivatives: Evaluating the Impact of New Regulation in Europe, Thomas He...DerivSource
Thomas Heinatz, Senior Manager, PwC
Presentation at the DerivSource/Omgeo briefing 'OTC Derivatives: Evaluating the Impact of New Regulation in Europe' held in Frankfurt on November 13th 2013.
IFRS 15 - the new revenue recognition standard EY Belgium
The IASB and the FASB have jointly issued a new revenue standard, IFRS 15 Revenue from Contracts with Customers, which will replace the existing IFRS and US GAAP revenue guidance.Find out more in our comprhensive brochure.
Baker Tilly Presents: New to Cost Reimbursement Contracts? Meet Your New Frie...BakerTillyConsulting
Presented at NCMA's World Congress 2016
Presenters: Baker Tilly's Brent Calhoon, CPA, Partner and Jennifer Flickinger, Partner
The world of cost reimbursement contracts has many exciting twists and turns. Contractors have to be ready to tackle the roller-coaster ride that comes with these complex contracts. This session provides an overview of some of the strict regulatory requirements that come into play as contract value and risk increase. The presenters will touch on the business system criteria, annual cost reporting requirements, the Cost Accounting Standards, and more. www.bakertilly.com/governmentcontractors
Taxmann's Webinar on Transfer Pricing Implications of the COVID-19 PandemicTaxmann
COVID-19 has created a spell of disruptions and changes that have left practically no facet of business untouched. OECD also recently released guidance on how to manage the impact of the pandemic in order to correctly apply the arm's length principle in intra-group transactions.
Since the ex-ante arm's analysis is time-sensitive, let’s hear from experts on the proposed solutions on the aforesaid framework and the upcoming challenges for taxpayers.
What is Value Added Tax (VAT)?
**An indirect tax imposed at each stage of production and supply.
**In general, the ultimate consumer is the one who bears the full cost of this tax while the business collects and
calculates the tax and pays it in favor of the state.
**A 5% is imposed on multiple production stages with the right to deduct taxes on inputs from taxes collected
from production outputs.
**The tax is collected each stage of the economic cycle (production, distribution, consumption)
Value added = Sale Price – Purchasing or Production cost
Disclosure of Transfer Pricing Policies: An Internal Prespectiveiosrjce
IOSR Journal of Business and Management (IOSR-JBM) is a double blind peer reviewed International Journal that provides rapid publication (within a month) of articles in all areas of business and managemant and its applications. The journal welcomes publications of high quality papers on theoretical developments and practical applications inbusiness and management. Original research papers, state-of-the-art reviews, and high quality technical notes are invited for publications.
Please join Unanet's Kim Koster, and BDO's Senior Associate, Tetiana Gervis, CPA , for an informative session to help in understanding your upcoming Incurred Cost Submission (ICS). The webinar will provide Government Contractors with an introduction to Incurred Cost Submissions, overview of preparation techniques and best practices, and common mistakes which could lead to scrutiny from the DCAA. Additionally, we will provide an update on the most recent DCAA audit trends.
You will learn about:
• Current ICS audit landscape
• General overview of the requirements of an ICS
• ICS schedules explanations
• ICS timeline and submission
• Common mistakes when preparing the submission and how these mistakes could lead to inadequacies and/or inquiries from the DCAA
If you would like to join Unanet for an upcoming webinar, please visit us at; https://www.unanet.com/webinars
When corporate or personal reputations are at stake, rapid response and access to the right resources are critical to stem the tide of potential regulatory, reputation and financial damage.
Poonawalla Fincorp and IndusInd Bank Introduce New Co-Branded Credit Cardnickysharmasucks
The unveiling of the IndusInd Bank Poonawalla Fincorp eLITE RuPay Platinum Credit Card marks a notable milestone in the Indian financial landscape, showcasing a successful partnership between two leading institutions, Poonawalla Fincorp and IndusInd Bank. This co-branded credit card not only offers users a plethora of benefits but also reflects a commitment to innovation and adaptation. With a focus on providing value-driven and customer-centric solutions, this launch represents more than just a new product—it signifies a step towards redefining the banking experience for millions. Promising convenience, rewards, and a touch of luxury in everyday financial transactions, this collaboration aims to cater to the evolving needs of customers and set new standards in the industry.
US Economic Outlook - Being Decided - M Capital Group August 2021.pdfpchutichetpong
The U.S. economy is continuing its impressive recovery from the COVID-19 pandemic and not slowing down despite re-occurring bumps. The U.S. savings rate reached its highest ever recorded level at 34% in April 2020 and Americans seem ready to spend. The sectors that had been hurt the most by the pandemic specifically reduced consumer spending, like retail, leisure, hospitality, and travel, are now experiencing massive growth in revenue and job openings.
Could this growth lead to a “Roaring Twenties”? As quickly as the U.S. economy contracted, experiencing a 9.1% drop in economic output relative to the business cycle in Q2 2020, the largest in recorded history, it has rebounded beyond expectations. This surprising growth seems to be fueled by the U.S. government’s aggressive fiscal and monetary policies, and an increase in consumer spending as mobility restrictions are lifted. Unemployment rates between June 2020 and June 2021 decreased by 5.2%, while the demand for labor is increasing, coupled with increasing wages to incentivize Americans to rejoin the labor force. Schools and businesses are expected to fully reopen soon. In parallel, vaccination rates across the country and the world continue to rise, with full vaccination rates of 50% and 14.8% respectively.
However, it is not completely smooth sailing from here. According to M Capital Group, the main risks that threaten the continued growth of the U.S. economy are inflation, unsettled trade relations, and another wave of Covid-19 mutations that could shut down the world again. Have we learned from the past year of COVID-19 and adapted our economy accordingly?
“In order for the U.S. economy to continue growing, whether there is another wave or not, the U.S. needs to focus on diversifying supply chains, supporting business investment, and maintaining consumer spending,” says Grace Feeley, a research analyst at M Capital Group.
While the economic indicators are positive, the risks are coming closer to manifesting and threatening such growth. The new variants spreading throughout the world, Delta, Lambda, and Gamma, are vaccine-resistant and muddy the predictions made about the economy and health of the country. These variants bring back the feeling of uncertainty that has wreaked havoc not only on the stock market but the mindset of people around the world. MCG provides unique insight on how to mitigate these risks to possibly ensure a bright economic future.
The secret way to sell pi coins effortlessly.DOT TECH
Well as we all know pi isn't launched yet. But you can still sell your pi coins effortlessly because some whales in China are interested in holding massive pi coins. And they are willing to pay good money for it. If you are interested in selling I will leave a contact for you. Just telegram this number below. I sold about 3000 pi coins to him and he paid me immediately.
Telegram: @Pi_vendor_247
how to sell pi coins at high rate quickly.DOT TECH
Where can I sell my pi coins at a high rate.
Pi is not launched yet on any exchange. But one can easily sell his or her pi coins to investors who want to hold pi till mainnet launch.
This means crypto whales want to hold pi. And you can get a good rate for selling pi to them. I will leave the telegram contact of my personal pi vendor below.
A vendor is someone who buys from a miner and resell it to a holder or crypto whale.
Here is the telegram contact of my vendor:
@Pi_vendor_247
The Evolution of Non-Banking Financial Companies (NBFCs) in India: Challenges...beulahfernandes8
Role in Financial System
NBFCs are critical in bridging the financial inclusion gap.
They provide specialized financial services that cater to segments often neglected by traditional banks.
Economic Impact
NBFCs contribute significantly to India's GDP.
They support sectors like micro, small, and medium enterprises (MSMEs), housing finance, and personal loans.
USDA Loans in California: A Comprehensive Overview.pptxmarketing367770
USDA Loans in California: A Comprehensive Overview
If you're dreaming of owning a home in California's rural or suburban areas, a USDA loan might be the perfect solution. The U.S. Department of Agriculture (USDA) offers these loans to help low-to-moderate-income individuals and families achieve homeownership.
Key Features of USDA Loans:
Zero Down Payment: USDA loans require no down payment, making homeownership more accessible.
Competitive Interest Rates: These loans often come with lower interest rates compared to conventional loans.
Flexible Credit Requirements: USDA loans have more lenient credit score requirements, helping those with less-than-perfect credit.
Guaranteed Loan Program: The USDA guarantees a portion of the loan, reducing risk for lenders and expanding borrowing options.
Eligibility Criteria:
Location: The property must be located in a USDA-designated rural or suburban area. Many areas in California qualify.
Income Limits: Applicants must meet income guidelines, which vary by region and household size.
Primary Residence: The home must be used as the borrower's primary residence.
Application Process:
Find a USDA-Approved Lender: Not all lenders offer USDA loans, so it's essential to choose one approved by the USDA.
Pre-Qualification: Determine your eligibility and the amount you can borrow.
Property Search: Look for properties in eligible rural or suburban areas.
Loan Application: Submit your application, including financial and personal information.
Processing and Approval: The lender and USDA will review your application. If approved, you can proceed to closing.
USDA loans are an excellent option for those looking to buy a home in California's rural and suburban areas. With no down payment and flexible requirements, these loans make homeownership more attainable for many families. Explore your eligibility today and take the first step toward owning your dream home.
Turin Startup Ecosystem 2024 - Ricerca sulle Startup e il Sistema dell'Innov...Quotidiano Piemontese
Turin Startup Ecosystem 2024
Una ricerca de il Club degli Investitori, in collaborazione con ToTeM Torino Tech Map e con il supporto della ESCP Business School e di Growth Capital
Falcon stands out as a top-tier P2P Invoice Discounting platform in India, bridging esteemed blue-chip companies and eager investors. Our goal is to transform the investment landscape in India by establishing a comprehensive destination for borrowers and investors with diverse profiles and needs, all while minimizing risk. What sets Falcon apart is the elimination of intermediaries such as commercial banks and depository institutions, allowing investors to enjoy higher yields.
Empowering the Unbanked: The Vital Role of NBFCs in Promoting Financial Inclu...Vighnesh Shashtri
In India, financial inclusion remains a critical challenge, with a significant portion of the population still unbanked. Non-Banking Financial Companies (NBFCs) have emerged as key players in bridging this gap by providing financial services to those often overlooked by traditional banking institutions. This article delves into how NBFCs are fostering financial inclusion and empowering the unbanked.
how to swap pi coins to foreign currency withdrawable.DOT TECH
As of my last update, Pi is still in the testing phase and is not tradable on any exchanges.
However, Pi Network has announced plans to launch its Testnet and Mainnet in the future, which may include listing Pi on exchanges.
The current method for selling pi coins involves exchanging them with a pi vendor who purchases pi coins for investment reasons.
If you want to sell your pi coins, reach out to a pi vendor and sell them to anyone looking to sell pi coins from any country around the globe.
Below is the contact information for my personal pi vendor.
Telegram: @Pi_vendor_247
how to sell pi coins on Bitmart crypto exchangeDOT TECH
Yes. Pi network coins can be exchanged but not on bitmart exchange. Because pi network is still in the enclosed mainnet. The only way pioneers are able to trade pi coins is by reselling the pi coins to pi verified merchants.
A verified merchant is someone who buys pi network coins and resell it to exchanges looking forward to hold till mainnet launch.
I will leave the telegram contact of my personal pi merchant to trade with.
@Pi_vendor_247
Even tho Pi network is not listed on any exchange yet.
Buying/Selling or investing in pi network coins is highly possible through the help of vendors. You can buy from vendors[ buy directly from the pi network miners and resell it]. I will leave the telegram contact of my personal vendor.
@Pi_vendor_247
how can I sell pi coins after successfully completing KYCDOT TECH
Pi coins is not launched yet in any exchange 💱 this means it's not swappable, the current pi displaying on coin market cap is the iou version of pi. And you can learn all about that on my previous post.
RIGHT NOW THE ONLY WAY you can sell pi coins is through verified pi merchants. A pi merchant is someone who buys pi coins and resell them to exchanges and crypto whales. Looking forward to hold massive quantities of pi coins before the mainnet launch.
This is because pi network is not doing any pre-sale or ico offerings, the only way to get my coins is from buying from miners. So a merchant facilitates the transactions between the miners and these exchanges holding pi.
I and my friends has sold more than 6000 pi coins successfully with this method. I will be happy to share the contact of my personal pi merchant. The one i trade with, if you have your own merchant you can trade with them. For those who are new.
Message: @Pi_vendor_247 on telegram.
I wouldn't advise you selling all percentage of the pi coins. Leave at least a before so its a win win during open mainnet. Have a nice day pioneers ♥️
#kyc #mainnet #picoins #pi #sellpi #piwallet
#pinetwork
2. 2
What do you know
about transfer pricing
in Indonesia?
3. 3
REGULATORY REQUIREMENT
A special relationship can
be triggered by:
• Direct or indirect share
ownership of 25% or more
• Common control (e.g.
management or
technology)
• Bloodline or by marriage
SPECIAL
RELATIONSHIP
• Embedded in Article 10 (1)
of Income Tax Law and
Article 2 (2) of VAT Law
and Article 9 of tax treaty
• Pricing of transactions
between parties with
special relationship must
be arm’s length
ARM’S LENGTH
PRINCIPLE
• Article 18(3) of Income
Tax Law gives DGT
authority to re-determine
the amount of income
and/or expense or debt as
equity using any of the
five arm’s length methods
(through an issuance of
tax assessment)
CONSEQUENCE OF
NON-ARM’S LENGTH
4. 4
THE WHAT, WHY AND HOW
WHAT
WHY
HOW
• The object of transfer pricing scrutiny is when pricing of transactions between related parties take
place under different conditions than those taking place between third parties
• The possibility of tax evasion through profit shifting from a high-tax jurisdiction (e.g. Indonesia at
25%) to a low tax jurisdiction (e.g. Singapore at 17% or lower) for cross border related party
transactions.
• The possibility of utilising different tax rate (e.g. final versus non final tax or when one of the
parties has fiscal loss balance) for local related party transactions.
• Through sales or purchase of tangible products
• Through transfer of intangibles (e.g. provision of services, technology, patent, etc)
• Through provision of financial services transactions (e.g. loan, guarantee fee)
5. 5
INDONESIAN TRANSFER PRICING MILESTONE
2008
1 Jan 2008
(PP 80/2007)
2009
2 July 2009
(PER-39/PJ/2009)
2010
31 Mar 2010
(S-153/PJ.04/2010)
Oct 2010
6 Sep 2010 – (Reg 43/PJ/2010)
3 Nov 2010 – (Reg 48/PJ/2010)
31 Dec 2010 – (Reg 69/PJ/2010)
Nov 2011
11 Nov 2011
May 2013
30 May 2013
Oct 2013
24 October 2013
TP
documentation
becomes
mandatory
TP Disclosure
form in CITR
introduced
(effective FY
2009)
DGT issues
internal TP
Guideline for
auditors Reg-43
Reg-48
Reg-69
Key TP Regulations
Reg-32
(Reg 32/PJ/2011)
Amendment of
Reg-43
Reg-22
(Reg 22/PJ/2013)
TP Audit Guidelines Circular 50
(Circular No 50/PJ/2013)
Implementation of
PER-22
6. 6
RECENT TRENDS
• In recent times, tax audit has become a challenging process for many taxpayers – especially those that have related party
transactions.
• The risk of getting more scrutiny in the area of transfer pricing increases, especially when the audited taxpayer fits into one or more
of the following conditions:
Significant volume
of related party
transactions in
proportion to sales
or net operating
income.
Cross-border
related party
transactions.
Special related
party transactions
such as provision of
services, payment
of royalties, and
payment of
interest.
Financial
performance that is
below industry
standards.
Perpetual losses.
Significant interest
expense, foreign
exchange loss/
income and loss/
income from asset
disposal.
Increased risk of scrutiny
7. 7
• For taxpayers who are expecting tax audit,
they may want to consider assessing its
position carefully and identify the potential
areas that the Indonesian Tax Office (“ITO”)
may challenge, then do an early preparation
to effectively mitigate the risks of challenges
that could lead to tax/transfer pricing
disputes.
• The first step in managing your transfer
pricing risk is to put in place
contemporaneous transfer pricing
documentation which is mandatory for the
following related party transactions:
• Those which are cross-border and with a
value of more than Indonesian Rupiah
(“IDR”) 10 billion per annum
(approximately USD 800,000) per
counterparty, or
• Those within Indonesia where there is an
opportunity to utilise “different” tax rates
(e.g. transactions with a company that is
subject to final tax) and again with a value
of more than IDR 10 billion per annum per
counterparty
• For related party transactions categorised as
“special transactions”, prepare the necessary
supporting documents (what is commonly
known as “Level 2 Documentation”) to satisfy
the necessity/existence test and the
economic benefits test which the ITO will
apply during tax audit.
• For future transactions, prepare a planning
study to ensure that implementing a pricing
model that can be supported from an arm’s
length principle perspective. For more
certainty, a taxpayer can also opt to apply for
Advance Pricing Agreement (“APA”).
MANAGING YOUR TRANSFER PRICING RISKS
8. 8
• Many taxpayers have formed a view that their transfer pricing compliance is only to prepare formal transfer pricing
documentation (i.e. testing exercise). This is a common mistake that has often led to significant transfer pricing assessments.
• Many have disregarded the need to undertake a price-setting exercise (i.e. transfer pricing planning study) to ensure they will
get an arm’s length return at year-end. Because of this, in many cases, taxpayers have returned year-end financial result that
is either below industry standard or (in some cases) are in perpetual losses for many years. Consequently, these taxpayers are
exposed to a high transfer pricing risk.
• Below is an illustration of the best practices to effectively manage your transfer pricing risks.
MANAGING YOUR TRANSFER PRICING RISKS (CONT’D)
Planning and price
setting
Drafting and
executing
intercompany
agreement
Determining
internal pricing
mechanism
Developing transfer
pricing policy and
procedures manual
Documenting and
compliance
Phase 1 Phase 2 Phase 3 Phase 4 Phase 5
Illustration 1 – Transfer pricing cycle
10. 10
HOW WE CAN HELP YOU
YOUR NEEDS REQUIREMENTS
REGULATORY
BASIS
OUR EXPERTISE YOUR BENEFIT
FIRST LAYER OF DEFENSE
Satisfying the Indonesian
formality requirement
Contemporaneous
transfer pricing
documentation (“TPD”)
that support CITR
disclosures (Form 3A and
3A-1).
Director General of Taxes
(“DGT”) Regulation No 32/
PJ./2011 (“Reg-32”)
Assisting with the
preparation of your formal
transfer pricing
documentation to reflect
a current year’s financial
and business performance.
• Enable identification of
key soft areas (gap
analysis).
•Develop action steps to
put in place defense for
these areas.
If your financial
performance for a
particular year is below
the industry average or in
a declining trend, you may
want to consider
undertaking Special Factor
Analysis (“SFA”). The
objective of this exercise is
to prove that the poor/
declining financial result
does not necessarily mean
it is a result of transfer
pricing practices.
• Get a head start to
collect supporting
documents to support
the analysis (and/or
adjustments when
appropriate).
•Take the opportunity to
develop defense
arguments.
•Take the necessary steps
to put in place additional
supporting documents as
appropriate.
11. 11
HOW WE CAN HELP YOU (CONT’D)
YOUR NEEDS REQUIREMENTS
REGULATORY
BASIS
OUR EXPERTISE YOUR BENEFIT
SECOND LAYER OF DEFENSE
Preparation of supporting
documents: [please note
there are just some
samples and therefore, is
not an exhaustive list. A
more comprehensive
review may be required to
identify your
documentation needs]
Sale/purchase of
product:
Commercial invoice,
Import documents,
purchase order, transfer
pricing policy
• DGT Regulation No 22/PJ./
2013 (“Reg-22”)
• DGT Circular Letter No 50/
PJ./2013 (“Circular 50”)
Assisting with tax/TP
diagnostic review
•Allow gap analysis to
minimize potential risk of
assessment due to non-
reconciling items (e.g.
between VAT and COGS).
Intra-group services and
royalty payments:
• Compilation of supporting
evidence (e.g. email
correspondence, report,
minutes of discussion,
travel documents, CV of
service providers, cost base
calculation, etc.)
• Narration to evident the
existence and economic
benefits they have brought
to the Company by linking
the company’s supporting
documents with the
transfer pricing principles
for intra-group services.
Assisting with Level 2
documentation review
• Increased possibility to
secure deductibility of
these expenses (in partial
or full amount) –
especially that these
transactions are
considered high risk
transactions. You may
want to consider
preparing your Level 2
Documentation if you are
expecting tax audit and
the transaction value is
above IDR 10 billion per
annum.
12. 12
HOW WE CAN HELP YOU (CONT’D)
YOUR NEEDS REQUIREMENTS
REGULATORY
BASIS
OUR EXPERTISE YOUR BENEFIT
SECOND LAYER OF DEFENSE : (CONT’D)
Completion of various
forms
In a tax audit event,
taxpayers will be
required to fill out ten
different forms in only
seven working days and
conduct a presentation
of its transfer pricing
position before the tax
audit team.
• Reg-22 Assisting with the
completion of the forms.
• Head start on
completion of these
forms and preparation of
defense arguments. This
will also ensure that the
Company’s responses on
the questions are
consistent with its
FY2014 CITR disclosures
and its transfer pricing
documentation.
• Early preparation of what
to present and
determining the
appropriate defense
strategy.
13. 13
HOW WE CAN HELP YOU (CONT’D)
YOUR NEEDS REQUIREMENTS
REGULATORY
BASIS
OUR EXPERTISE YOUR BENEFIT
ASSISTANCE WITH TRANSFER PRICING DISPUTE
RESOLUTION
Local avenue: Assistance
with transfer pricing
audit, filing tax objection
and filing tax appeal to
the tax court.
International avenue:
Assistance with Mutual
Agreement Procedure for
transaction with a tax
treaty country.
• To ensure requests from
the ITO (or the Tax
Court judges in case of
tax appeal) are
addressed in a timely
manner.
• To ensure provision of
data/information
consists of those
requested and not those
that could potentially
open an area for
dispute.
• Art.18 of Income Tax Law
• OECD Transfer Pricing
Guidelines
• Reg-22
• DGT Circular No.50/PJ/
2013
• Advising you on how to
best present data/
information to the ITO
or tax court judges.
• Assisting you to put
forward technical
arguments that would
strengthen your transfer
pricing position.
• Guiding you in every
step of the process and
advising your rights as a
taxpayer.
• Sharing with you our
past experience and
collaborating with you
to develop an effective
defense strategy.
• Reducing efforts in
preparing documents/
information that are not
necessary for your
defense.
•Having a more structured
defense strategy and
implementation.
•As transfer pricing audits
(objection and appeal)
tend to be fact-intensive,
we will guide you to
strike a balance between
providing critical facts of
your business/industry
and ensuring discussions
with the authorities are
still conducted in
consideration of the
transfer pricing technical
aspects.
14. 14
HOW WE CAN HELP YOU (CONT’D)
YOUR NEEDS REQUIREMENTS
REGULATORY
BASIS
OUR EXPERTISE YOUR BENEFIT
TRANSFER PRICING PLANNING
Legal certainty for future
related party
transactions through
planning and/or APA
• Adherence to the arm’s
length principle before
and after transactions.
• Reduce unnecessary
costs of transfer pricing
disputes.
•Compliance to Base
Erosion Profit Shifting
initiatives of the OECD
member countries.
• Art.18 of Income Tax Law
• OECD Transfer Pricing
Guidelines
• BEPS action plan
• Reg-22
• PMK No 7/PMK.03/2015
regarding APA procedure
• Assisting with the pre-
lodgment phase.
• Assisting with
preparation of the
planning document.
• Assisting with the
preparation of the
Advance Pricing
Agreement Application.
• Assisting you in the
discussions with the tax
authorities.
• Reduce the risk of future
transfer pricing disputes.
•Ensure obtaining an arm’s
length outcome from
transactions – which will
help strengthen your
position during tax audit.
Robust transfer pricing
policy
• A policy that is
consistent with the
arm’s length principle
yet able to
accommodate your
business needs.
• OECD Transfer Pricing
Guidelines
• Assisting you in ensuring
the policy is in line with
the planning study.
• Advising you with the
necessary Level 2
documents.
• Having a business
process that is in
compliance with the
Indonesian arms length
requirements.
15. 15
• We have a dedicated team of transfer pricing specialists who have vast
knowledge in various industry segments, including: manufacturing and
distribution of consumer products (fast moving consumer goods and
consumer electronics), plantation (palm oil), energy (e.g. geothermal, oil
and gas), utilities and mining (e.g. coal, copper, gold and nickel),
hospitality, chemicals.
•A strong global network in 151 countries that operate through 1,328
offices across the globe. The BDO International network shares common
culture & passion aligned around parallel themes of:
•Quality People. We focus on investing in & hiring the best & insist on
strong personal relationships throughout firm & network; and
•Quality Service. We provide quality service based not only on
technical expertise, but also on business acumen, commercial
awareness & local knowledge.
•One clear defining aspect of the BDO network is its belief that working
relationships between people are key factor. The network is known for its
close involvement with clients, getting to know them & their business
needs while always maintaining human perspective.
WHY US?
16. For more information please contact:
PT BDO BISNIS SOLUSI INDONESIA
Michelle Mianova (mmianova@bdo.co.id)
BDO Indonesia
Prudential Tower 16th-18th Floor
Jl. Jenderal Sudirman, Kav. 79
Jakarta 12910, INDONESIA
Tel : +62-21 5795 7300
Fax : +62-21 5795 7301
www.bdo.co.id
About BDO
BDO is the one of the largest global network of public accounting,
tax and advisory firms which perform professional services.
These firms have representation in 154 territories, with 64,300
people working out of over 1,400 offices worldwide.
BDO member firm in Indonesia dated back to 1992 when
Drs Richard B Tanubrata was the Managing Partner of
KAP Drs RB Tanubrata, a public accountant firm that
was founded in 1979.