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Indonesia Publishes New Regulation on Advance Pricing Agreements Including Profit Rate Conditions and Adjustments for COVID-19

07 October 2020

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Approved Changes

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Indonesia

Indonesia's Directorate General of Taxation (DGT) has published Regulation No. PER-17/PJ/2020 on procedures for the application, implementation, and evaluation of Advance Pricing Agreements (APAs). The regulation is effective from 17 September 2020 and replaces the prior regulation on APAs issued in 2010, Regulation No. PER-69/PJ/2010.   Regulation No. PER-17/PJ/2020 includes that taxpayers may apply for an APA based on: taxpayer's own initiative for requesting a unilateral or bilateral APA; or written notice from the DGT in connection with a bilateral APA application submitted by foreign taxpayers to the competent authority of a tax treaty partner. When making an APA request, it...