Implementation of Advance Pricing Agreement Regulation as Transfer Pricing Dispute Prevention in Indonesia

IJSRP, Volume 12, Issue 2, February 2022 Edition [ISSN 2250-3153]

Implementation of Advance Pricing Agreement Regulation as Transfer Pricing Dispute Prevention in Indonesia

Agnes Lazuardi

Abstract: In March 2020, the Ministry of Finance issued a PMK-22/2020 which stipulates the Advance Pricing Agreement whilst aligning the Indonesian advance pricing agreement regulation with BEPS Action 14 to provide more legal certainty. As a form of adoption, PMK-22/2020 stipulates new provisions such as extension of the definitions of special relationship which are not stipulated in Article 18 paragraph 4 of the Income Tax Law.

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Agnes Lazuardi (2022); Implementation of Advance Pricing Agreement Regulation as Transfer Pricing Dispute Prevention in Indonesia; International Journal of Scientific and Research Publications (IJSRP) 12(2) (ISSN: 2250-3153), DOI: http://dx.doi.org/10.29322/IJSRP.12.02.2022.p12238