How to Make Transfer Pricing Documentation in Indonesia

Indonesia has been issued The Minister of Finance (MoF) of Republic Indonesia Regulation No. 213/PMK.03/2016 and PER No. 29/PJ/2017. The MoF issued based on BEPS (Base Erosion and Profit Shifting) Action 13 which specifically regulate about Guidance on the Implementation of Transfer Pricing Documentation and Country-by-Country Reporting (CbCR). Based in BEPS Action 13, the format of CbCR Multinational Enterprise (MNE) Groups require such as information:

  1. List of Member of MNE, including their principal business activities each jurisdiction (specifically refer to Appendix F of MoF No. 123)
  2. Allocation of Income (specifically refer to Appendix G of MoF No. 123) each jurisdiction from all member of MNE

Company in Indonesia that must be provide transfer pricing documentation are based on criteria in link here.

Transfer Pricing Documentation (TPD) consist of some overview, analysis and explanation of transfer pricing method. Here’s some point in TPD:

  1. Executive Summary, consist of Purpose of Report and Summary of all conclusion analysis
  2. Scope of Report, consist of Coverage and Limitations
  3. Company Overview, consist of group overview, including ownership structure, business strategy and operation, and financial performance.
  4. Industry overview
  5. Function Analysis
  6. Transfer Pricing Regulation in Indonesia, consist of transfer pricing method that used by the company.
  7. Intercompany Transaction, consist of the analysis and application of transfer pricing method in the transaction.

Overall, TPD were used for examine implementation of arm’s length principle that MNE use between related parties transaction and third parties transaction.

Digital Money, The Investment of Digital World

Global transaction world recently full of digital transaction. Foreign exchange is one of easier option for making money as well as we known the value is depending on economy, politic, supply and demand of society environment. There’s too much payment gateway that our society can use it as an instrument of cashless payment which mean that digital transaction provide safety guarantees for society to save their money well. When we relate this phenomenon with any regulation in any country, we mostly found that our government do extensive in regulation for increase supervision on resident cash flow, including source of addition of assets that we have from our transaction.

Digital money, electronic cash (such as Bitcoin) offer unique solution for any investor who want to keep their money as well and don’t want pay tax for that transaction, especially when they got addition for assets undetectedly by bank or intermediaries. Each country have their own regulation to manage cash flow from their resident and detect it for economic and tax importance. In otherwise, the resident especially some kind of people don’t like to give contribution to their own country pass through tax. There’s no secret too for big company do the same thing, but usually they use individual name to do investment company importance (such as family business company for example). Digital money transaction is hard to tracing by government. This path using by individual, company or even political elite to hiding their assets in overseas, specifically in country which accept payment with digital money such as bitcoin, etc. This phenomenon was help this kind of investor to heap assest in digital as much as they could.

Digitalization is accepted easier and faster lately, dynamical of economic development was increase each second of time by invention and technology innovation. There’s make any different function from traditional transaction tracing to modern transaction tracing, here means automatically result of tracing by AI (Artificial Intelligence) to be threats for any government to control transaction of it, as how to tracing the transaction, built the international law between one country to the other country, and watch over all the network so any provider must be report the website whose used by society.

Based on data, people name that mentioned in Panama Papers case (2016) is mostly come from wealth class and famous people who have much money and have digital assets with high value. It’s show that much potensial of income tax or data that lost by government to trace. In government side, on the implemetation of built the frame structure for regulate the phenomenon is needed time and effort. One of the crucial thing in this case need investation for big data. Big data is one of many big corporation invest for because of the value in the future. It’s kind of big investation for government to take this phenomenon as an preparation for built the frame work structure for tracing any potential transaction related to digital transaction on people in their country, specifically Indonesia who doesn’t accept digital money such Bitcoin as tool of payment.

On the other hand, investation in digital world thrive significantly. Currently, people choose investation which give easy way to get the information about the investation, friendly to use (related to application or website), and have potensial of high return. Therefore, society start to have investation in digital world, in any kind of valuable thing  such as digital money which offer good return in the future.