Recognition of Permanent Establishment under the China-Indonesia Tax Agreement丨Indonesia Tax Guide 2025 (53)
In the China-Indonesia Tax Agreement, the term "permanent establishment" refers to a fixed place of business where an enterprise conducts all or part of its business.
China-Indonesia Tax Agreement
Permanent Establishment
2025-03-28 09:10:13 Page view:140
Scope of Application of the China-Indonesia Tax Agreement丨Indonesia Tax Guide 2025 (52)
The scope of application of the China-Indonesia Tax Agreement includes the subject scope, object scope and territorial scope of the agreement.
China-Indonesia Tax Agreement
Scope of application
2025-03-27 13:50:28 Page view:210
Indonesia's Double Taxation Agreement and China-Indonesia Taxation Agreement丨Indonesia Tax Guide 2025 (51)
Currently, Indonesia has signed bilateral tax agreements with 71 countries and regions in the world.
Indonesia Double Taxation Treaty
China-Indonesia Tax Agreement
2025-03-26 09:09:24 Page view:208
Determination criteria for thin capitalization and tax adjustments | Indonesian Tax Guide 2025 (50)
The current regulations set out the maximum debt-to-equity ratio for corporate taxpayers established or registered in the United States.
Indonesia
Weak capitalization
2025-03-24 08:42:00 Page view:243
Main contents of cost sharing agreement management and tax adjustments丨Indonesia Tax Guide 2025 (49)
(1) Regulations require that services between related parties be priced on an arm’s length basis;
Indonesia
Cost Sharing Agreement
2025-03-24 08:39:39 Page view:226
Controlled Foreign Corporation Determination Criteria and Tax Adjustments丨Indonesia Tax Guide 2025 (48)
The Ministry of Finance has the authority to assess dividends received by resident taxpayers from the following non-listed foreign companies:
Indonesia
Controlled foreign companies
2025-03-22 09:08:45 Page view:251
Scope and Procedures of Advance Pricing Arrangements丨Indonesia Tax Guide 2025 (47)
Advance pricing arrangement management refers to the Indonesian Tax Bureau's review and evaluation of the pricing principles and calculation methods of related-party transactions proposed by enterprises in future years in accordance with relevant regulations, and negotiation with enterprises to reach an advance pricing arrangement. This arrangement applies to taxpayers with large-scale related-party transactions.
Indonesia
Advance Pricing Arrangement
2025-03-20 09:10:58 Page view:284
Transfer Pricing Investigation Notes | Indonesian Tax Guide 2025 (46)
The preparation phase should be mainly carried out according to the laws and regulations of the investigation agency, and the tax audit officials should focus on collecting information on the production and operation status of the enterprise. The enterprise should provide the tax bureau with information on related-party transactions in the first phase of the investigation.
Indonesia
Transfer pricing investigation
2025-03-19 09:11:44 Page view:304
Principles and main methods of transfer pricing investigation | Indonesian Tax Guide 2025 (45)
When enterprises have related relationships, there is a possibility that income or expenses are underestimated or exaggerated, resulting in a reduction in taxable income. In this case, the tax bureau has the right to make special tax adjustments based on reasonable methods to ensure that the related transactions of enterprises comply with the principle of independent transactions.
Indonesia
Transfer pricing method
2025-03-18 09:05:12 Page view:301
Specific Requirements and contents of Transfer Pricing Documents - Indonesia Tax Guide 2025 (44)
The Regulation requires taxpayers to prepare and submit transfer pricing documents, including proof that the affiliated enterprise transaction complies with the principle of a separate transaction. Local documents and main documents should be prepared within four months from the end of the fiscal year and submitted in accordance with the requirements of the tax bureau.
Indonesia
Transfer pricing documentation requirements
2025-03-17 08:48:55 Page view:289
Transfer pricing classification and preparation entities | Indonesian Tax Guide 2025 (43)
Transfer pricing documentation is divided into master file, local file and country-by-country report. Transfer pricing documentation should be in Indonesian. Where approval is obtained to use English, taxpayers may provide English documents and attach an Indonesian translation.
Indonesia
Transfer pricing documentation
2025-03-14 09:09:18 Page view:340
Basic Types of Related-Party Transactions丨Indonesia Tax Guide 2025 (42)
The tax authorities have the power to make special tax adjustments for all types of transactions between related parties, to reallocate income and deductions between related parties, and to treat debt as equity to calculate the taxpayer's taxable income based on the arm's length principle.
Indonesia
Related-party transactions
2025-03-13 09:09:59 Page view:362
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