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PrimeTax

03 — Transfer Pricing

Transfer Pricing Advisory and Documentation

Assess related-party transactions, prepare documentation that reflects how your business actually operates, and understand where transfer pricing risk sits.

Client situations

When Companies Engage Us

Documentation obligations

Companies with related-party transactions may be required to prepare a Master File and Local File, depending on applicable thresholds.

Intragroup services and royalties

Management fees and royalties are frequently examined for evidence of benefit and arm's length pricing.

Business model changes

Changes in functions, assets, or risks — such as converting a distributor or centralising procurement — affect expected profitability.

Profitability under scrutiny

Sustained losses or low margins in an entity with related-party transactions may draw questions during audits.

Scope of assistance

What We Cover

Transfer Pricing Risk Assessment
Review of related-party transactions to identify where pricing, documentation, or characterisation creates risk.
Master File and Local File
Preparation or review of transfer pricing documentation consistent with the group's actual functions, assets, and risks.
Benchmarking Analysis
Search and analysis of comparable companies or transactions to support the arm's length range.
Related-Party Transaction Review
Review of agreements, invoices, and evidence supporting specific related-party transactions.
Intercompany Pricing Review
Evaluation of pricing policies and year-end adjustments against the selected transfer pricing method.

Engagement process

How the Work Is Structured

  1. 01

    Understand

    Interview management to understand the value chain, group structure, and transactions.

  2. 02

    Assess

    Analyse functions, assets, and risks; test pricing and documentation against requirements.

  3. 03

    Advise

    Prepare documentation and explain risks, assumptions, and recommended changes.

  4. 04

    Support

    Assist with updates, information requests, and alignment with the group's global policy.

Considerations

Regulatory and Technical Context

Current framework

Indonesian transfer pricing documentation and the arm's length principle are governed by PMK-172/PMK.03/2023, which consolidated earlier rules. Thresholds and timelines should be confirmed against the regulation for each year.

Substance over form

Documentation must reflect actual conduct. Agreements that differ from how the business operates provide limited protection.

Consistency with the group

Local documentation should be consistent with the group's global transfer pricing policy and with information reported in other jurisdictions.

Summary for general information only. Regulations are applied to the specific facts of each engagement.

How we present exposure to management

Likelihood
LowMediumHigh

Impact

Illustrative framework. Actual ratings depend on the facts of each engagement.

FAQ

Frequently Asked Questions

Is every company with related-party transactions required to prepare a Local File?

Not necessarily. Requirements depend on thresholds and on the nature of the transactions. We review your facts against the current regulation to confirm what applies.

Can you review documentation prepared by our group's global advisor?

Yes. We can review global documentation for consistency with Indonesian requirements and with how the local entity operates, and recommend local supplements where needed.

Do you assist with Advance Pricing Agreements?

Please discuss APA or MAP matters with us directly. We will confirm the scope of assistance we can provide for your specific situation.

Related

Related Services and Insights

Review Your Transfer Pricing Risk.

Share the context of your matter. We will propose a scope and approach for an initial discussion.