FORMATION AND IMPLEMENTATION AGREEMENT TRANSFER PRICE (ADVANCE PRICING AGREEMENT)

Filing Transfer Price Agreement (Advance Pricing Agreement) hereinafter abbreviated APA can be done by the taxpayer within Indonesia and abroad Taxpayers conducting business or engaged in activities through permanent establishments in Indonesia, or the taxpayer in the country or jurisdiction Partner Partner Country. 



 Taxpayers in the Indonesian domestic and foreign taxpayers can file submission Transfer Price Agreement (Advance Pricing Agreement) along been operating or conducting business in Indonesia at least 3 (three) years. Filing Transfer Price Agreement (Advance Pricing Agreement) or APA conducted through the State Tax Authority Jurisdiction Partner or Partner, covers the whole or part of the transactions carried out by the taxpayer with Related parties. 

Filing Transfer Price Agreement (Advance Pricing Agreement) or APA valid and binding upon the Director General of Taxation with the taxpayer or the Director General of Taxes to the taxpayer and the State Tax Authority Jurisdiction Partner or Partner. 

The submission period of the implementation of Transfer Price Agreement (Advance Pricing Agreement) or APA, no later than 3 (three) years or a maximum tax of 4 (four) years of tax for the APA that the discussion  involves the State Tax Authority Jurisdiction Partner or Partner.