Regulation Update
New Provisions Released, Submission of TP Doc Maximum One Month from Request

Friday, 12 January 2024

New Provisions Released, Submission of TP Doc Maximum One Month from Request

The government regulates the deadline for submitting transfer pricing documentation (TP Doc) reports, to a maximum of 1 month since requested by the Directorate General of Taxes (DGT). 

However, the deadline for the availability of TP Doc remains, which is a maximum of four months from the closing book. 

This is one of the substances in the recently released regulation, Minister of Finance Regulation (MoF) Number 172 Year 2023 on the Application of The Arm's Length Principles in Transactions Affected by Special Relationships.

Read: MUC Consulting Named One of the Best Tax and Transfer Pricing Firms in 2024 Based on the ITR Version

This provision has been in effect since the regulation was promulgated on 29 December 2023.

The new things regulated in PMK 172/2023 are related to the application of the Arm's Length principles in transactions affected by special relationships for domestic taxpayers that meet the provisions as Permanent Establishments (BUT).

In addition, PMK 172 Year 2023 also rearranges the qualifications related to the cancellation of secondary adjustment and the application of the Profit Split Method (PSM) which is more detailed than the previous provisions.

Furthermore, PMK 172 Year 2023 provides affirmation to prioritize the use of a single year. On the other hand, multiple years can be used if it increases the level of comparability.

For more details, the detailed provisions can be seen through the following link. PMK 172 of 2023.



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