18 Apr 2017
Catenaccio ala TP Docs
For soccer mania, catenaccio is a familiar word in soccer game. Catenaccio or the chain is a tactical system in soccer with a strong emphasis on defence. In Italian, catenaccio means “door-bolt” / (‘grendel’ in bahasa) which implies a highly organized and effective backline defence focused on nullifying opponents’ attacks and preventing goal-scoring opportunities (source: https://en.m.wikipedia.org/wiki/catenaccio).
Per MOF No.213/PMK.03/2016, taxpayers that having affiliated transaction should be prepared Transfer Pricing Documentations (TP Docs). I have written the article on threshold for taxpayers who have the obligation to prepare TP Docs in my previous article (link: http://tax-legal.id/update/new-tax-regulation-on-transfer-pricing-issues/60).
Tax offices may ask the 2016 TP Docs after the period to file the Corporate Tax Return i.e. April 30, 2017. They can test and review (‘attack’) the logical reasoning and the supporting comparable data in the TP Docs.
In order to defense that affiliated transactions based on fair market independent value, the taxpayers should prepare:
The above 3 reports, Master File, Local File and CBCR is part of Catenaccio in defending the affiliated transactions, as arm’s length price. One and anothers are strongly related and as a whole defensive strategy. TP Docs is an art like strategy in soccer. Soccer composition strategy can be 4-3-3, 4-4-2, WM, total football, tiki-taka or even 1-3-5-2, where a 'goalie' become as a sweeper. There is no a fixed formula how to prepare a good TP Docs.
TP Docs is not a science but an art!!
Agung Tjahjady SH, CPA, MM, BKP
Registered Tax Consultant, Advocate
0816 825 348
BVD Oriana User
Read Other Updates
TP Docs Series:
26 Mar 2018
CFC Rules in Indonesia
01 Mar 2018
Tax Amnesty: Pengisian dan Pelaporan Penempatan Harta Tambahan
27 Feb 2018
Ke Bank Indonesia atau ke Otoritas Jasa Keuangan-kah Pendaftaran Perusahaan Fintech yang Kudirikan
26 Feb 2018
Menanti Ijin E-money Perusahaanku
15 Feb 2018
Automatic Exchange of Financial Account Information Singapore - Indonesia
18 Jan 2018
Things You Need To Know Before Establishing E-Commerce Company In Indonesia
03 Jan 2018
What Are The Important Issues For Setting Up A Peer To Peer Lending Company In Indonesia?
19 Dec 2017