As the world wide implementation of BEPS Action Plans, Tax authorities around the globe strive to enhance their domestic laws to comply with the Plans. It has a huge impacts on how to structure the related party transactions and to make sure the current transactions satisfy the newly adopted regulation e.g. aligning the outcome with the value creation. The aforementioned points are complying with three core principles in the post-BEPS era promoted by OECD such as improving global coherence of tax laws, tightening economic substances, and ensuring transparency.
At TaxPrime, we equip ourselves with unique seasoned and in-hand experience professionals to deliver you with the excellence services on:
- Transfer Pricing Bench-marking, Planning and Re-structuring.
As Indonesian Tax authority promotes the implementation of ex-ante approach, therefore, transfer pricing benchmarking and planning is the fundamental steps should be taken by MNEs to develop a robust and defendable transfer pricing policy in the group. Further, the restructuring would be needed to revise the current policy to ensure the BEPS Actions requirements.
- Transfer Pricing Monitoring.
Once the transfer pricing in Indonesia policy has been set, one of the most crucial stage in the implementation of the Transfer pricing policy is transfer pricing monitoring. The monitoring is important in continuously ensuring that the pricing policy has been properly applied e.g. outcome aligns with the value creation.By periodically monitoring the pricing policy e.g. quarterly, MNEs may have a chance to reconsider or formulate a new transfer pricing policy reflecting the current facts and circumstances encountered by company. The implementation of TP monitoring may increase the transfer pricing compliance level e.g. satisfying requirements as required by MoF 213/2016 and reducing compliance cost resulting from tax dispute.
- A Three-tiered Transfer Pricing Documentations (Master File, Local File, and CbCR).
A well-thought and tailored-made transfer pricing documentation may result in defendable, high compliance level, and less risk adjustment made by Indonesian Tax Authority. At TaxPrime, We have developed a unique approach to examine the related party transactions, therefore, in case of dispute, the adjustment risk will be mitigated.
- Transfer Pricing Diagnostic Review.
We can perform review of your overall transfer pricing documentation and inter-company arrangements to identify opportunities for structuring tax-efficient business operation and recommend best practices for your inter-company transactions.
- Transfer Pricing Dispute Resolution (Transfer Pricing Audit, Objection, Appeal, APA, and MAP).
At the time the dispute arises, it is important to have a clear and robust strategy to defend our position. Accordingly, to grasp and to identify possible adjustment, at early of our assignment, we will deeply analyze our clients’ position and documentations. Additionally, while we are strictly maintaining our code of conducts and integrity, we have been well-known for having a developed-communication with Indonesian tax officials that equips us to deliver and address tax disputes more effectively.
- International Tax and Transfer Pricing Training.
Since the International Tax and Transfer pricing issues become inevitable issues encountered by MNEs, there is increasing demand in establishing in-house team to deal with the aforementioned issues. Building a solid and competent team would be challenging and time consuming for companies, subsequently, we provide a training inspired from our in-hand experiences and the most current debate in the relevant area. Therefore, it enables you to understand and solve your international tax and transfer pricing issues.
- Assistance in International Tax Issues.
As the Tax Authorities eager to comply with the OECD recommendations, the international tax landscape is changing. For MNEs, not-complying cross border transactions means exposing itself to high risk tax adjustments and scrutiny by Tax Authorities.To minimize any cross border tax issues, we provide you with a comprehensive and helicopter international tax knowledge, therefore, your business may not be distracted by tax issue.