Globally, transfer pricing has captured the attention of tax authorities who are keen to ensure their fair share of global tax revenues. In the last decade, transfer pricing has evolved into one of the most challenging tax issue faced by tax professionals. With its potential to have a significant impact on the effective tax rate, organizations must pay close attention to their transfer pricing policies, documentation and reporting. With the onset of domestic transfer pricing, these issues are not limited to multinational enterprises alone, but impact businesses in the domestic space as well. The developments on the policy front, including the prescription of harmonised tax law regulations has the potential to impact the transfer pricing policy of the businesses.

Our team assists Indonesian and Multi-National Corporations develop and implement economically justifiable transfer pricing policies and documentation.

Our team have significant experience in transfer pricing matters and have worked on developing and implementing solutions for clients in several sectors related to complex transfer pricing issues. We help businesses in developing and implementing effective transfer pricing strategy and policies as well as in preparation of transfer pricing documentation (including for meeting CbCR requirements). We also have extensive experience in transfer pricing dispute management and in assisting clients with Advance Pricing Agreements (APA), both unilateral and bilateral.


Our transfer pricing services include:

  • Transfer Pricing Documentation – we assist businesses to design and implement a suitable compliance policy with an appropriate level of documentation.
  • Transfer Pricing Planning & Supply Chain Structuring – we provide assistance in developing and implementing economically viable Transfer Pricing policies including policy support for business restructuring.
  • Litigation Support / Transfer Pricing Controversy Management – we help clients  develop strategies and appropriate documentation to  support and manage the tax audit/appeal proceedings.
  • Advance Pricing Arrangements – we can assist preparing a robust Transfer Pricing policy aligning with business and commercial substance along with deciding on various documents and information that need to be shared with tax authorities during the course of negotiating and implementation of an APA program.


How we can help you with Tax Services


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