We are excited to announce the release of our latest newsletter, highlighting the long awaited Minister of Finance Regulation Number 172 of 2023 (MoFR-172), or as we call, The New Indonesian Transfer Pricing Guidelines.

Indonesia’s transfer pricing landscape is poised for a transformation with MoFR-172. This pivotal regulation, centered on the Implementation of the Arm’s Length Principle (Prinsip Kewajaran dan Kelaziman Usaha/PKKU), marks a strategic response to recent amendments in the Income Tax Law and the General Provisions and Procedures of Taxation Law. These are aligned with the harmonization of Tax Regulations Law, further defined by GR-50 and GR-55 of 2022. MoFR-172 introduces vital changes in how transfer pricing, Mutual Agreement Procedure (MAP), and Advance Pricing Agreement (APA) are conceptualized and implemented, signaling a progressive step towards refining tax compliance and fairness in business practices.