On 18 March 2020, Indonesia’s Ministry of Finance (MoF) has released Regulation number 22/PMK.03/2020 (PMK-22), Guidelines for the Establishment and Implementation of Advanced Pricing Agreements, which repeals the prior regulation on advanced pricing agreements (APA). The stated intent of PMK-22 is to align Indonesia’s APA framework with the OECD/ G20 BEPS project, to provide greater legal certainty as well as to make the APA program more effective. PMK-22 provides a number of significant developments which include the following, among other things:  (1) An APA can now cover five forward years as well as open historical years under a rollback, subject...