000			02651nab a2200229 c 4500
999			_c143572 _d143572
003			ES-MaIEF
005			20210211130812.0
007			ta
008			210211t2020 ne ||||| |||| 00| 0|eng d
040			_aES-MaIEF _bspa _cES-MaIEF
100	1		_968741 _aAstuti, Melani Dewi
245		0	_aImplementation of BEPS recommendations in Indonesia’s new APA and transfer pricing rules _c Melani Dewi Astuti
260			_c2020
500			_aDisponible también en formato electrónico.
500			_aResumen.
520			_aIndonesia has recently updated its Advance Pricing Agreement and transfer pricing regulations in order to capture the development in the business and transfer pricing. It is also aimed to align with the Base Erosion and Profit Shifting (BEPS) recommendations. The new regulation has made substantial changes to the old advance pricing agreements (APAs) and transfer pricing regulations. With regards to transfer pricing, the new regulation has made some changes pursuant to the related parties’ definition, transfer pricing methods, comparability analysis procedures, special transactions, and intangibles. The transfer pricing guidance also provides guidance on the financial transactions and introduces the value creation concept. The new definition of related party is broader by providing more example on the ownership based on control. The regulation also allows the use of other transfer pricing methods other than the five OECD methods. Moreover, the intangible provisions have been modified to reflect the changes in the OECD Transfer Pricing Guideline 2017, to cover development, enhancement, maintenance, protection, and exploitation (DEMPE) activities and the economic owner. The guidance on financial transaction could also be useful for taxpayers and tax administration. Meanwhile, in terms of APA, the new regulation has provided a longer period of APA implementation, included a roll-back provision and modified the requirements regarding the submission of APA. Based on the new APA regulation, to submit an APA, a taxpayer cannot propose a lower profit than profit reported in the tax return. In general, the new regulation is in line with the BEPS 8-10 recommendations, albeit some differences are found, those are considered minor. The new regulations are expected to provide more certainty and simplicity for the taxpayers.
650		4	_967933 _aACUERDOS PREVIOS SOBRE PRECIOS DE TRANSFERENCIA
650		4	_948095 _aPRECIOS DE TRANSFERENCIA
650		4	_947477 _aINDONESIA
773	0		_9164289 _oOP 2141/2020/12 _tIntertax _w(IEF)55619 _x 0165-2826 _gv. 48, Issue 12, December 2020, p. 1145-1154
942			_cART