Indonesia's Directorate General of Taxation (DGT) has issued Regulation No. PER-16/PJ/2020 of 11 August 2020 regarding the application of the mutual agreement procedure (MAP) rules provided by Regulation No. 49/PMK.03/2019, including procedures for making MAP requests. This includes that taxpayers may submit MAP requests to the DGT as the competent authority in cases where the tax treatment by the tax authorities is not in accordance with the provisions of an applicable tax treaty. In particular, Regulation No. PER-16/PJ/2020 provides that a request for the implementation of MAP by the DGT may be made where the tax treatment by the DGT...