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TAXATION

Transfer Pricing Documentation & TP Audit Defense

Preparation of TP Documentation (Master File, Local File, CbCR) and transfer pricing audit assistance for affiliated companies.

2-4 Months Starting from Rp 35 Million
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What's Included

What this service covers

Master File & Local File preparation
Country-by-Country Reporting (CbCR)
Functional & comparability analysis
Benchmarking with international databases
TP audit defense & negotiation
Advance Pricing Agreement (APA) consultation
Package Scope

What's included in this package

TP Documentation - Local File

Preparation of Local File with functional analysis, comparability study, and benchmarking for Indonesian entities.

2-3 Months Starting from Rp 35 Million

Master File for Corporate Groups

Preparation of Master File containing the global profile of multinational corporate groups.

2-3 Months Starting from Rp 50 Million

Transfer Pricing Audit Defense

Assistance during transfer pricing audits by the DGT and preparation of defense documentation.

6-18 Months Starting from Rp 50 Million
Preparation

Documents you'll need to prepare

Our team will guide you through each item — providing templates and format standards where needed.

Group company & affiliate structure
List of intercompany transactions for 3 years
Group consolidated financial statements
Agreements with affiliated parties
Business profile of all group entities
Why Bizmark.ID?

Without Bizmark vs. With Bizmark

See the real difference in process speed, outcomes, and risk exposure.

Without Bizmark

  • Slower process — independent research takes weeks, often with dead ends.
  • Document rejection risk due to incorrect format or missing requirements.
  • No status visibility — uncertain when permits will be issued.
  • Error costs can reach IDR 50–200M if a wrong step is taken.

With Bizmark.ID

  • Accelerated process — experienced team knows exact requirements and workflows.
  • Documents prepared to standard — 96% approval rate across all clients.
  • Weekly SLA reports — you always know your permit status.
  • Staged payment: 50% upfront, 50% on permit issuance.
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FAQ

Frequently Asked Questions

Who is required to prepare TP Documentation?
Taxpayers with affiliated transactions >Rp 50 billion/year, or certain transactions >Rp 5 billion/year (according to PMK 213/2016).
What are the consequences of not having TP Doc?
The DGT can make unilateral adjustments using methods and comparables chosen by the DGT, usually detrimental to the taxpayer. Plus administrative penalties of 50% of underpaid tax.
What is CbCR?
Country-by-Country Reporting — a multinational group report containing distribution of revenue, taxes, and activities by country. Mandatory for groups with global consolidated revenue of Rp 11 trillion.
What is APA?
Advance Pricing Agreement — a written agreement between the taxpayer and the DGT (and other tax authorities for bilateral APA) about the TP method to be used, providing legal certainty.
How much does TP Doc preparation cost?
Starting from Rp 35 million for a simple Local File to hundreds of millions for complex multinational groups with many affiliate transactions.

Ready to move your permits forward?

Our team guides you from the first consultation through to permit issuance — on schedule, every time.

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