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Indonesia Consolidates and Updates Transfer Pricing Regulations

06 February 2024

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Approved Changes

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Indonesia

Indonesia has published Minister of Finance (MoF) Regulation No. 172 of 2023, which updates and replaces prior regulations regarding transfer pricing documentation, mutual agreement procedures, and advance pricing agreements. The chapters of the updated and consolidated transfer pricing regulations cover: General Provisions; Special Relationships (Related Parties); The Application of the Arm's Length Principle; Documentation of the Application of the Arm’s Length Principle (i.e., transfer pricing documentation); Assessment of Compliance in the Application of the Arm’s Length Principle Corresponding Adjustments; Mutual Agreement Procedure; Advance Pricing Agreement; The Submission of Decision Letter Documents; Transitional Provisions; and Closing Provisions. Notable additions and changes...