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Transfer Pricing: 2017 Revised Ide, Strategi, dan Panduan Praktis dalam Perspektif Pajak Internasional Edition

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Darussalam* Indonesia and Freddy Karyadi** Tax Treatment of Derivatives

Darussalam and Freddy Karyadi 1. Introduction atives transactions are treated for income tax purposes.6 This article will examine the treatment of various deriv- The public awarenessing into in the Indonesia contract. with Futures regard contracts to deriva are- an equivalent sumption or increasing the taxpayer’s wealth, in whatever name atives transactions fromand form, an Indonesianincluding: tax perspective. tive instrumentsof and forward the implications contracts that thereof are publicly began in traded. the l gains from foreign exchange [...]13 1990s when theFutures media andreported forwards that areseveral recognized well-known as an asset 2.or aIncome liab- Tax Treatment domestic companies and banks suffered significant losses ility on the inception1 date, rather on the date on which set- on derivatives tlementtransactions. takes place. Again Other in 2008, than many that, comthere- are noArticle further 4(1) ofArticle the Income 6(1)(e) Tax of IncomeLaw recognizes Tax Law a36 broad of 2008 states that: panies (includingrequirements state-owned under enterprises) GAAP. which Correspondingly, invested theconcept degree of “taxable Residentobject”, taxpayers which is and “any permanent increase establishments in eco- are entitled to in currency derivativeof probability transactions at inception were affectedwould also by thenot be accountednomic capacity receivedclaim the by deductions or accrued in the by form a taxpayer”.of expenses to earn,Tax Treatment to collect of Derivatives impact of the financialfor under crisis GAAP. and suffered massive losses. On the other hand,and article secure income6(1)(a) from of theirthe grossIncome income, Tax including: These losses motivated the Indonesianlying assets, tax derivatives authorities transactions to Law are regarding normally directlyloss [...]recognition with has the a holder’s limited exercisescope, and right. The tax treatment of the conduct tax auditsPrior to to safeguard 5 Junecategorized 2011, the national gains as speculativefrom tax base.futures financial contractsincludes instruments. were “costs which are directlypremium or indirectly paid by therelated writer to and received by the holder subject to a final withholding tax of 2.5% of thethe initialbusiness”. The eclarification losses fromfollows foreign of articleGAAP, exchange 6(1)(a)8 such that of thethe holder and writer recognize In general, Indonesia has twoThere tax treatments are generally of derivatives no other specific11 regulations regard- margin. Following a 2009 Supreme Court Case,Income futures Tax Law further statesthe premium that deductible as an asset expen and- liability, respectively. transactions: listed and over-the-counter.ing derivatives With transactions regard to in the Income Tax Law.2.1.3. As Recognition issues and forward contracts are currently treated equallyditures and also include expenditures for activities involv- listed futures contracts, a finalsuch, withholding GAAP governs tax of the 2.5% treatment of derivatives trans- In the context of the case studies, the journal entries of are subject to the normal2 income tax rate of 25%ing on earning, net collectingDerivatives and effectively securing income transfer as the a taxable risks inherent in an of the initial margin shall12 actionsapply. forAs incomefrom June tax purposes.2011, In this regard, PSAK 55 a derivatives contract at inception should be made as income. Under GAAP (PSAK 55), there is no differenceobject. underlying primary instrument between the contract- however, the Supreme Courtdistinguishes abolished this between regulation derivatives as transactions of a specu- follows. in treatment between listed futures and over-the-counter ing parties without any need to transfer the underlying a result of a judicial review decision.lative nature3 Therefore, and of a allhedging types nature.In aIndicative private ruling, factors7 theof tax authorities provided the fol- forwards. instruments themselves.Table 1 Under PSAK 55, all derivatives of derivatives transactions (whetherwhether over-the-counterderivatives transactions or arelowing of a hedging interpretation nature, in the context of derivatives trans- Under PSAK i.e.55, designatedthe foreign for exchange reducing contract risk, are: accounts are recognizedCase at fairCompany value on Accountthe balance sheet, withDebit any Credit listed contracts) are currently treated similarly for income actions: (1) A cash 4 are valued by using– whether the future the exchange enterprise rate forhas the exposure remain- to riskchanges that in value reported in profit and loss. tax purpose. – gains from derivatives transactions are– taxableoption contract for 4 ing contract term. affectsAt the itsend income of the bookstatement; year, there incomeis an taxWhen purposes a financial (whether asset designated or financial for liabilityspecu- is recognized Since to date there are no specific income tax regulations (2) B option contract 4 entry adjusting– thewhether payable derivatives to its appropriate contracts balance are specificallylative at or hedginginitially, entered purposes); an entity must measure it at its fair value plus; regarding tax treatment of derivatives in Indonesia, a rec- – cash 4 the statement of financialinto in order position. to hedge The payable underlying –currency lossesexposure; fromin derivatives the case of transactions a financial assetthat could or financial be rec- liability not at ognition of income or expense and the time of recogni- (3) C option contract 2 transaction income– the or effectiveness loss is reported of inthe the hedge; income stateognized- forfair income value throughtax purposes profit are and limited loss, transaction only if costs that tion in the Income Tax Act (ITA) must follow the general – cash 2 ment, usually– under reliable “Other measurement income (loss)”. of the effectivenesssuch lossesare ofare directlythe incurred attributable in relation to to the the acquisition business. or issue of the provisions regarding accounting for tax purposes as stip- (4) E cash 1 hedge; and Losses incurredfinancial by asset a taxpayer or financial as a consequenceliability. of ulated in articleUnder 28(7) ofPSAK the General55, recognition Provisions of andforeign Tax exchange for – option contract 1 – formal documentation of the hedgingderivatives relationship transactions at with the purpose of hedging Procedures Law.hedging4 Accounting foreign forexchange tax purposes liability refers by using to futures con- After initial recognition, an entity must value financial the inception of the hedge. its underlying assets, are considered to meet the the generally acceptedtracts are marked-to-marketaccounting principles and (GAAP)settled on a daily basis, assets, includingNo derivativesother journal that entries are assets, than at the their above fair are required requirements for deductible losses; and as commonly appliedas follows: in Indonesia.A derivatives5 The provisionstransaction for not considered as a hedgingvalue, without under any deductionGAAP at the for inception transaction of an costs option that contract. Cor- – losses incurred from derivatives transactions that are derivative transactions wouldinstrument be found inis thenormally PSAK 55.classified as “speculativethe finan entity- mayrespondingly, incur on sale the or otherdegree disposal, of probability except of for an option con- At inception: of a speculative nature are not deductible for income cial instrument designated for profit making”. the following tractfinancial at inception assets: (whether in-the-money or out-of-the- Under PSAK 55,Company “derivative F is obliged instrument” to buy isThere defined is the as same a entry tax purposes, as these derivatives transactions do not USD 100 at a price of EUR 100 for hedge accounting and – loans andmoney) receivables, is not which accounted must befor valued under at GAAP. amor- financial instrument or otherFurthermore, contract with under the following GAAP, gain or losshave realized a relation in spec to- the taxpayer’s business. at T2; current exchange rate speculative transactions. tized costUnder using Casethe effective Study (2), interest Company method; B’s position, if it already characteristics:USD 95 : EUR 100ulative transactions must be recognized in the profit and In the authors’– opinion, held-to-maturity the heldtreatment a participating investments, of taxable interest objectswhich must in X shares,be valued could be classi- – its value changesDuring lifein response of contract:loss account, to a change while in an the under treatment- of gain or loss realized and deductible expensesat amortized following cost the using clarification the effective of the interest method; 9 lying; The exchange ratein hedgingchanges to transactions Record daily depends settlement on itsof effectiveness and fied as an available-for-sale financial instrument. Conse- Income Tax Law reflectsand a symmetry that should treat both – no initial netUSD investment 101 : EUR 100is recognizedis required inorfutures eitherthe value contracts. the profitis and loss account or the quently, any changes in fair value of the financial instru- sides in an equivalent– investments manner, i.e.in equity if certain instruments income falls that do not have a less than that of similarother contracts comprehensive that manifest income the account (a balance sheet ment would be booked in the other comprehensive under taxation, the comparablequoted market expenses price on also an must active be market rec- and the fair same effectUnder towards PSAK changesaccount). 55, an in interestmarket However, factors;rate accumulatedswap and to hedge gain/loss foreign recognized in income account. On the other hand, Company B’s posi- ognized and deductedvalue in ofdetermining which cannot taxable be reliably income. measured, As as well as – it is settledexchange at a certain liability datethe otherin by the using comprehensive future. futures contracts income is account marked- could be reclas- tion, if it is held for a short transaction, could be classi- to-market andsified settled in aon later a daily period basis, into as thefollows: profita result and lossof the account. ambiguityderivatives in thefied Income that as financialare Tax linked Law, asset to however, and at fair must value be throughsettled by profit and loss, Furthermore, circulars and private rulings issued by the in practice the tax authoritiesdelivery ofi.e. would such it is unquoted acquiredin most cases or equity incurred not instruments, rec- for the purpose which of selling or tax authorities couldAt inception: provideAny insight gains on howrecognized certain derivin the- profitognize and loss deductible account losses mustare frombe valuedrepurchasing a derivatives at cost. it transactionin the near term if (held for trading).10 Con- Case Study (4): consideredBank G has taxableThere income. is the same In entry thisthe forcontext, transaction article is not 4(1) of a hedging nature (reducing risk of entered into an interest rate both hedge accounting and Financial assetssequently, that are any designated changes asin hedgedfair value items will beare booked based of the Income Tax Law recognizesan both underlying the realization asset). Moreover, in the absence of under- swap with Bank H. Bank G speculative transactions subject to valuationon mark-to-market under hedge accounting.in the profit and loss account. As the buys long-termprinciple interest rate and of the accrual principle in determining taxable Income Tax Law is silent, GAAP provisions as described * Managing Director of Danny Darussalamobjects. As Tax there Center, is Jakarta.no specific regulation regarding deriva- ** Partner, Ali Budiardjo,3% against Nugroho, variable Reksodiputro 6 months law offices, Jakarta. As, generally, aboveGAAP would governs also the be treatment applicable of to derivatives the tax treatment. Euribor (at starttives 1.4%) transactions on a for tax purposes,6. however, Circular article SE-51/PJ.22/1986,transactions 28(7) 11 for Nov. income 1986, regarding tax purposes, currency swapderivatives for tax 1. Darussalam, Transaksinotional Derivatif principalof dan the of Aspek EUR General 10Perpajakannya Provisions, in Kapita and Tax Procedurescontracts; LawCircularpurposes would SE-12/PJ.313/1993, are recognizedThe same18 May 1993,GAAPat fair regarding value. apply forward under Case Study (3), where Selekta Perpajakanmillion (Jakarta: at a Salembamaturity Empat, of 2 years.2007), at 57. sales of foreign exchange; Private Ruling S-245/PJ.101/1997, 21 May 2. Government Regulation No. 17 ofapply, 2009. such that, in principle, the tax treatment1997, regarding will followwithholding taxCompany of swap transactions; C’s position, Circular ifSE-03/ it already held a portfolio or if it 3. Supreme Court Case 22P/HUM/2009.the accounting treatment in accordancePJ.43/1993, with 9 Feb.GAAPGAAP. 1998, regardingdetermines already swaps andthat held forwards gain a participating ofor deposit loss interest;realized interest, in specula would -be classified as 4. General ProvisionThe and tax Tax treatment ProceduresAccordingly, Law of as gains lastly asamended or GAAP losses by Lawrecognizes due No. to fluctuating gain orCircular loss SE-13/PJ.43/1999,on thetive basis transactions 22 Mar.held 1999, mustfor regarding trading be recognized swaps and and available-for-sale forwards in the profit respectively. and 28 of 2007. of deposit interest; Private Ruling S-300/PJ.42/2003, 3 June 2003, foreign exchangeof the rates mark-to-market follows GAAP. principle, the same principleloss alsoaccount, while the treatment of gain or loss realized 5. Statement of Financial Accounting Standards (Pernyataan Standar regarding cross-currencyin hedging interest transactionsUnder swaps. Case depends Study (4), on itsif Company effectiveness E held rec- a naked posi- Akuntansi KeuanganArticle, PSAK) 4(1)( 55.l)applies of Income for tax Tax purposes. Law 36 of 2008 7.states Private as Ruling S-300/PJ.42/2003. ognized in thetion profit (the and option loss accountcontract or is thenot other designated com- for hedging follows: prehensive incomerisk), the account transaction (a balance concerned sheet couldaccount). not normally be DERIVATIVES & FINANCIAL INSTRUMENTS2.1. Entering – SPECIAL into ISSUE derivatives – AUGUST 2012 © IBFD 68 A taxable object is income, which is defined as any increase in However, accumulatedconsidered gain/loss as an effective recognized hedge, in but the ratherother of a specula- economic capacity2.1.1. Optionsreceived by or accrued by a taxpayer from comprehensivetive income nature. account Any changes could bein reclassifiedfair value of in the a option con- Indonesia as well as from offshore, which may be utilized for con- tract would be booked in the profit and loss account. An option is a contract that gives the option holderlater theperiod into the profit and loss account. Accordingly, right to execute the call or put it upon the underlyingGAAP asset recognizes gain or loss on the basis of the mark- 11. 22P/HUM/2009, available at http://www.iflr.com/Article/2480664/ 2.1.2. Futures and forwards Hong-Kong-tax-treaty.html.at a certain price, which is determined as the strike price 12. Art. 17 Incomebefore Tax Law. the expiration date. An option embodies13. the folAuthors’- translation.A forward contract is an agreement between a buyer and lowing elements: a seller that requires the delivery of some commodity at a – the option holders are given the right (not the obliga- specified future date at a price agreed at the time of enter- 70 DERIVATIVES & FINANCIAL INSTRUMENTS – SPECIAL ISSUE – AUGUST 2012 © IBFD tion) to exercise (buy or sell) a certain asset; – there is a strike or exercise price; and 8. PSAK 55, para. 14. – there is a maturity date. 9. PSAK 55, para. 8 (available-for-sale financial assets are those non-derivative financial assets that are designated as available for sale Typically, the writer of the option contract will collect or are not classified as (1) loans and receivables, (2) held-to-maturity a premium for assuming the obligation in accordance investments or (3) financial asset as fair value through profit and loss). 10. PSAK 55, para. 8.

© IBFD DERIVATIVES & FINANCIAL INSTRUMENTS – SPECIAL ISSUE – AUGUST 2012 69

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7 8 Indonesia Adopts CbC Reporting & New TP Doc Requirements MoF 213/2016

Since the release of BEPS action 13, regarding to guidance on transfer pricing documentation and country-by-country reporting (CbCR), G20/OECD member countries has been agreed to implement the minimum standard consistently. As part of Indonesia's commitment to the implementation of the standard, the Ministry of Finance released on 30 December 2016, decree no. PMK-213.03/2016 (MoF 213/2016), the much-anticipated regulation on CbCR and its corresponding updates to transfer pricing documentation requirements. The standard called Three-tiered Approach.

(Appendix D, MoF 213/2016) Specific business operations, Local Financial information, Affiliated transactions, File Transfer pricing analysis of the covered affiliated transactions

(Appendix C, MoF 213/2016) MoF 213/2016 MNE group global operations, Master Required if* MNE transfer pricing policies. File

MoF 213/2016 CbCR Required if*

(Appendix E, F, G, MoF 213/2016) Gross revenue in one tax year Report information on affiliated parties, >IDR50,000,000,000; Amount of revenue, Profits, Accumulated affiliated transaction for: Income tax paid and accrued, Tangible transactions Employees, >IDR20,000,000,000; Retained earnings and assets, FAR Analysis by each entity. Penalty Services, Intangible, or other transactions MoF 213/2016 Non-compliance Events Consequences >IDR5,000,000,000; Conduct related party transactions Transfer Pricing Deemed as not to with a lower statutory tax rate than Required if* documentation is not based have applied the Indonesia (<25%). on contemporaneous data arm’s length and information. principle. Parent entity with a (Article 3, MoF 213/2016) consolidated revenue In case of late >IDR11,000,000,000,000*; submission, TP Doc cannot be considered in SYNOPSIS MASTER & LOCAL FILE Subsidiaries with one or Non-compliance during the remaining course of the ongoing procedure Should be attached Should be available more parent entity is tax monitoring audit with CITR due to 4 due to 4 months after resident in: prelimenary/tax crime In case of failure months after the end the end of taxable investigation. submission, deemed as of taxable year. year. Country with no CbCR not to have conducted obligation; or an appropriate (Appendix B, MoF 213/2016) bookkeeping

Country with no EoI Deemed as not to agreement; or Failure to submit statement CbC REPORTING letter and/or CbC report have conducted Should be available due to 12 months after Country with EoI during tax return filing. an appropriate the end of taxable year; and agreement but CbCR bookkeeping. Should be attached with the next CITR. cannot be obtained. Taxpayers that are not required to prepare TP Doc are still * obligated to apply the Arm’s Length Principle. 2016 April 2017 April 2018 2019 Example: Bookkeeping Jan-Dec 2016. Example: Bookkeeping Jan-Dec 2016. Operational Transfer Pricing

Background Firefighting & Continuous adhoc analysis monitoring Based on transfer pricing regulations, . No uniform . Avoids Year-end intercompany margins must be at arm’s length. application adjustments This often evidenced by benchmarking data, internationally (there . Margin monitoring which are available years later, if not during is no guidance and throughout the the time of audits, when these margins will be often no regulations year . tested. Not surprisingly discrepancies could as well) Opportunity for a . Risks: corrective action be discovered because these benchmark . Double taxation/ by updating prices data were not available for the multinational in corresponding during current year when the transactions were executed. The country not tax in order to steer principal factor is time, or in other words, what deductible margin proactively . . information is available at what time. Therefore, Accounting treatment Fewer . VAT/Customs controversies and the issue is how can your company act or react . Credit/debit entry reduced risks to ensure an arm’s length behavior in your (operational issue): intercompany transactions. what must be described in the Why is operational transfer pricing document? . important? Secondary adjustments/ withholding tax The risk of “out of control” intercompany profit issues margins and the likelihood of material year- end adjustments can be effectively countered by continuous monitoring of intercompany Previous margins, through effective operational transfer transfer pricing pricing management. documentation practice hypothetical

ad hoc continuous price setting firefighting analysis monitoring

ex-post ex-ante empirical outcome testing Firefighting & Continuous adhoc analysis monitoring

. Outcome testing tool . Proactive . Results in Year-end intercompany adjustments/ ex-post margin adjustments/ one-off management/ compensation, to price setting bring intercompany approach/ profits in line with operational operational Arms length profits transfer pricing/ Year-to-go outcome testing adjustments

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Operational . Review at the end of Hypothetical price . Prepare target margin outcome testing the fiscal year, whether setting at the beginning of new deviation from target fiscal year margin is acceptable . Integrate target margin or not to business plan and . Advice whether to budget preparation conduct year-end . Inform target margin adjustment Operational price setting to stakeholders Empirical outcome . Revise hypothetical (controllers and sales testing target margin with managers) available data at the . Systematically integrate end of the fiscal year target margin to retail price, volume forecast . Document every step Contemporaneous and preparation of cost of the transfer pricing transfer pricing budgets management process documentation in accordance with Operational . Conduct quarterly MoF 213/2016 monitoring and reviews, deviation analysis from the price updating forecast . Detect early on whether deviation is likely . Conduct corrective action by updating MoF 213/2016 price during current contemporaneous year to steer intercompany margins transfer pricing hypothetical documentation requirements price setting

operational price setting

operational monitoring & price updating

11 Our Transfer Pricing Specialists

DDTC’s specialists have in-depth transfer pricing knowledge obtained from well- known universities abroad and transfer pricing skills international certificates.

and Technology, Chamber of Commerce and Industry, Indonesian Fiscal and Tax Administration Association, Indonesian Tax Consultants Association, Indonesian Institute of Accountants) and some universities (the University of Indonesia, Brawijaya University, Airlangga University, Gadjah Mada University, Parahyangan Catholic University, Tarumanagara University, Trisakti University, Petra Christian University, Bina Nusantara University, Christian University of Indonesia, Sebelas Maret University).

DARUSSALAM

Darussalam is Managing Partner of DDTC. His main academic focuses are international taxation and comparative tax law. He is acknowledged as a tax expert witness in various tax cases at the District Court, the Corruption Court, the Tax Court and the Constitutional Court. In addition, he has recently been chosen as the government’s expert witness in Tax Amnesty Law judicial review. He received a Master’s degree in Tax Policy and Administration from the University of Indonesia, and DANNY SEPTRIADI a second Master’s degree (LLM) in European and International Tax Law from European Tax College (at Tilburg University in the Netherlands and Katholieke DANNY SEPTRIADI is the Senior Partner of DDTC Universiteit Leuven in Belgium). His master thesis and a lecturer at Graduate Program in Tax Policy and is entitled “Critical Analysis on Indonesian Transfer Administration Science and at Master in Accounting Pricing Rules: a Proposal for Indonesian Transfer Pricing Program at the University Of Indonesia. He was Guidelines”. selected as one of the World’s Leading Transfer Pricing Advisers 2015 by Expert Guides. He was In 2009, he successfully completed an advanced transfer experienced in Arbitration Disputes as an expert in pricing course from Thomas Jefferson School of Law, London, United Kingdom and he is an expert witness San Diego, California, USA. In 2011, he attended the of PT Kraft Indonesia, PT General Food Industries in “Asia Pacific Transfer Pricing Summit 2011” held by IBC the Indonesian tax court. His main research areas are Legal Conference in Hong Kong and also a seminar on international taxation and transfer pricing. He also “European Tax Law” held by Tax Academy of Singapore serves as a Secretary at Indonesian International and the Institute for Austrian and International Tax Tax Society (IITS). He has advised clients in various Law, Vienna University of Economics and Business areas of corporate taxation, tax risk management and Administration, in Singapore. In 2012, he attended transfer pricing. “Summer School of Value Added Tax Programme” held by Universidade Católica Portuguesa, in Lisbon, He received a Master’s degree in Tax Policy and Portugal. In 2015, he attended “International Tax Administration from the University of Indonesia, and a Conference: BEPS & Beyond” held by Foundation For second Master’s degree (LLM) in International Taxation International Taxation, in Mumbai, India. from Vienna University of Economics and Business Administration, Austria, with master thesis on tax Darussalam is the author of several books (6 books) treaty policy. In 2012, he attended “Summer School and numerous articles on taxation (127 articles). He of Transfer Pricing Programme” held by Universidade is a source for print media (Kompas, Kontan, Bisnis Católica Portuguesa, in Lisbon, Portugal. In 2014, Indonesia, Tempo Magazine and Newspaper, Sinar he attended “Advanced Course in Transfer Pricing” Harapan, Suara Pembaruan, Jawa Pos, Rakyat Merdeka) held by Maastricht Centre for Taxation, Maastricht and electronic media (TV One, Metro TV, RCTI, SCTV, University, in The Netherlands. Then, in 2015, he TVRI, Berita Satu, Jak TV, Kompas TV, ANTV, Sindo attended “Transfer Pricing: Policy and Practice” held TV, Detik. com, BBC Indonesia), and also a speaker at by Duke Center International Development (DCID), several institutions (Directorate General of Taxes, Fiscal Duke University North Carolina, USA. Policy Agency, Corruption Eradication Commission, Secretariat of Tax Court, National Economic Committee, Danny Septriadi has published several books and Bank Indonesia, PUSDIKLAT Pajak, Ministry of Research numerous articles on transfer pricing and international taxation. He is a source for print media (Kompas, He is a regular speaker in various seminars and Bisnis Indonesia, and Kontan), and also a speaker trainings organized by DDTC, covering topics in at several institutions (Directorate General of Taxes, Transfer Pricing. He is frequently involved as a trainer Fiscal Policy Agency, Secretariat of Tax Supervisory and speaker in several forum and group discussions Committee, Secretariat of Tax Court, PUSDIKLAT held by private institutions and government agencies Pajak, Indonesian Institute of Accountants, University including Tax Office (KPP) Madya Sidoarjo, Fiscal of Indonesia, Bina Nusantara University). Policy Office of Ministry of Finance and Secretariat of Tax Court, PUSDIKLAT Pajak, PajakOnline and Formasi, Secretariat of Tax Supervisory Committee, Centre of Investment, Finance and Energy Studies (CIFES), Faculty of Economics of the University of Indonesia, Bina Nusantara University, Tax Center FISIP UI, Sinar Mas Group, Unilever, Kalbe Group, and others.

ROMI IRAWAN

Romi Irawan is the Partner of Transfer Pricing Services at DDTC. He is an experienced practitioner in transfer pricing controversies. He has vast experience in handling transfer pricing issues for clients involved in crude palm oil, automotive, pulp, and chemical industries. DAVID HAMZAH DAMIAN He received his Bachelor’s degree in Financial Management from the University of Indonesia, David Hamzah Damian is the Partner of Tax Master’s degree in Corporate Financial Management Compliance & Litigation Services at DDTC. He is well from Gadjah Mada University and he received his next known for his research and advocacy skills, in particular Master’s Degree in International Taxation (LL.M. Int. for analyzing cases and arguing appeals. He regularly Tax) at Vienna University of Economics and Business handles cases in Tax Court, and has a strong track Administration – Austria, under full scholarship from record in tax appeal proceedings in transfer pricing, DDTC. value added tax, corporate income tax, and custom cases, both in writing submissions and at hearings. He is In 2010, he participated in distance learning courses also the co-author of the Indonesian chapter in the third on “transfer pricing”, held by the International edition of a book titled “the Tax Disputes and Litigation Management Forum in association with Transfer Review”, published by Law Business Research. Pricing Associate, the Netherlands. In 2011, he attended many transfer pricing workshops, seminars He received his Bachelor’s degree in Fiscal and courses, on “Advanced Transfer Pricing Workshop” Administration from the University of Indonesia, and held by IBFD in Amsterdam, the Netherlands, currently he is pursuing his Master’s degree in Tax Policy “Global Development in Transfer Pricing” held by and Administration at the University of Indonesia, under Tax Academy of Singapore, in Singapore, “Transfer scholarship from DDTC. Pricing Workshop on Transfer Pricing Documentation In 2010, he attended a course on “Transfer Pricing and Transfer Pricing Intangibles” held by IBC Legal Aspects of Business Restructurings” organized by Conference, in Hong Kong, and “UK Transfer Pricing IBFD, in Singapore. Further, in 2011 he attended the Policy and Developments” held by Tax Academy “Annual International Taxation Conference” held by the of Singapore, in Singapore. In 2012, he attended Foundation for International Taxation, in Mumbai, India, “the First Annual Conference Series regarding U.S. and attended the “Tax Treaties” seminar, held by Tax Transfer Pricing Primer” organized by Bloomberg Academy of Singapore and the Institute for Austrian and BNA and CITE, in Salt Lake City, United States of International Tax Law, Vienna University of Economics America. In April 2014, he attended “Transfer Pricing and Business Administration, in Singapore. In 2012, Advanced Course Programme” organized by Transfer he attended the “Asia Pacific Branch – Singapore Pricing Research Center, Leiden University, in Leiden, Conference 2012”, held by the Chartered Institute of the Netherlands. Taxation in Singapore, and also a course on “Tax Risk He has passed two out of three examination papers Management” held by IBFD, in Singapore. In 2013, he for Advance Diploma in International Taxation from attended “the Amsterdam Centre for Tax Law Winter the Chartered Institute of Taxation – UK, including Course on International Tax Law”, held by the Amsterdam Principles of International Taxation and Principles Centre for Tax Law of the University of Amsterdam, in of Corporate and International Taxation (Transfer the Netherlands, and “Summer School of Value Added Pricing), and therefore has been awarded Certificate Tax Programme” held by the Universidade Católica in Principles of International Taxation and Principles of Portuguesa, in Lisbon, Portugal. Corporate and International Taxation (Transfer Pricing). He has passed two out of three examination papers Fiscal Analysis, and Revenue Forecasting”, held by for Advance Diploma in International Taxation from Andrew Young School of Policy Studies, Georgia State the Chartered Institute of Taxation – UK, including University, USA. Advance International Taxation: Singapore Option; and Principles of International Taxation, and therefore has B. Bawono Kristiaji holds Advanced Diploma in been awarded a certificate in Principles of International International Taxation; Certificate in Principles of Taxation. He has completed certificate C of Indonesian International Taxation; and Certificate of Principles of Tax Consultant Examination and has been licensed Corporate and International Taxation (Transfer Pricing) to practice as a registered tax consultant. He holds a from the Chartered Institute of Taxation, UK. license to practice as a tax attorney by the Tax Court. He is a major contributor for the latest DDTC’s transfer He is frequently involved as a trainer, lecturer or pricing book titled “Transfer Pricing: Ide, Strategi, dan speaker in several tax trainings or seminars, held by Panduan Praktis dalam Perspektif Pajak Internasional”, DDTC, governmental institutions, private institutions, the chief editor for DDTC Working Papers and and universities, including House of Regional senior editor for InsideTax Magazine. He is an active Representatives of Republic Indonesia, the South member of the Indonesian Fiscal Association (AFI) and Jakarta Medium Tax Office (KPP), Secretariat of Tax Indonesian Fiscal and Tax Administration Association Supervisory Committee, the Bali Chapter of Indonesian (IFTAA). He is a source for print and electronic media Tax Consultant Association, TELKOM Group, Kalbe (Jakarta Post, Republika, BeritaSatu, MNC Business, Group, PAMA Persada Nusantara, the Accountant Bisnis Indonesia, and Bloomberg). Professionalism Study of Faculty of Economics of the He is a regular speaker in various seminars and trainings University of Indonesia, the Fiscal Administration Study organized by DDTC, covering topics in Transfer Pricing. Group of the University of Indonesia, Christian University He is frequently involved as a trainer and speaker in of Indonesia and so forth. several forum and group discussion held by private institutions and government agencies including Forum on Economic and Fiscal Policy (The Netherland), 21st International Taxation Conference 2016 (FIT, India), House of Representatives of the Republic of Indonesia, House of Regional Representatives of the Republic of Indonesia, Directorate General of Taxes, Fiscal Policy Agency, Secretariat of Tax Court, Secretariat of Tax Supervisory Committee, International Tax and Investment Center, BAPPENAS, Ministry of Research and Technology, PUSDIKLAT Pajak, Institute of Indonesia Chartered Accountants (IAI), Astra International, KALBE Group, University of Indonesia, and others covering topics in tax policy trends.

B. BAWONO KRISTIAJI

B. Bawono Kristiaji is the Partner of Tax Research & Training Services at DDTC. He is an experienced practitioner in public finance, tax policy, and transfer pricing. Prior to joining DDTC, he worked as researcher in Strategic Asia, a consultancy firm specializing in economic development policy. He received his Bachelor’s degree in Economics from the University of Indonesia, received his Master’s Degree in Economic Science at the same university with the thesis titled “The Implication of Shadow Economies and Governments’ Effectiveness on Realization and UNTORO SEJATI Effort to Optimize Tax Revenue”. He received his next Master’s Degree in International Business Tax and Economics (MSc. IBT) at School of Economics and Untoro Sejati is the Senior Manager of Transfer Management, Tilburg University, the Netherlands under Pricing Services at DDTC. He has been involved in han- scholarship from DDTC with the thesis titled “Incentives dling transfer pricing controversies, as well as design, and Disincentives of Profit Shifting in Developing review, implementation and documentation of transfer Countries”. This thesis was chosen as the best work in pricing policies with emphasis on accounting analysis. the area of European Taxation by Confédération Fiscale Européenne (CFE), and therefore was awarded Albert He received his Bachelor’s degree in Accounting from J. Rädler Medal 2015. the University of Indonesia and currently pursuing his Master’s Degree of Law in International Taxation In 2012, he attended a course of the Master of (LL.M. Int. Tax) class of 2015-2016 at Vienna Advanced Studies in International Tax Law on University of Economics and Business Administration “Transfer Pricing Rules in International Taxation” held - Austria, under full scholarship from DDTC. by the International Tax Center, Leiden University, in Leiden, the Netherlands. In 2013, he attended Public In 2011, he attended a workshop on “Permanent Policy Summer Training Course 2013 “Tax Policy, Establishment” held by IBFD, in Singapore. In 2012, he attended a workshop on “Advanced Transfer a regular speaker in various seminars and trainings Pricing Workshop” held by IBFD in Amsterdam, the organized by DDTC, covering topics in international tax Netherlands. In April 2015, he attended “Transfer Pricing and transfer pricing. He is regularly invited as a speaker Advanced Course Programme” organized by Transfer in tax conferences organized by government institutions Pricing Research Center, Leiden University, in Leiden, and universities, including the Directorate General of the Netherlands. He holds Certified Public Accountant Taxes, Fiscal Policy Agency, Secretariat of Tax Court, (CPA). Indonesian Tax Consultants Association, the University of Indonesia, the Petra Christian University (Surabaya), He is also frequently involved as a trainer or speaker in PT Wijaya Karya (Persero) Tbk, PT Mayekawa Indonesia, several tax trainings or seminars, held by DDTC, Unilever, PT Growth Asia and others.a Kalbe Group, PT Astra International Tbk, Indonesian Tax Consulting Association (IKPI), the Institute of Indonesia Chartered Accountant (IAI), Fiscal Policy Agency, Secretariat of Tax Court, Secretariat of Tax Supervisory Committee, and others.

GANDA CHRISTIAN TOBING

Ganda Christian Tobing is the Senior Manager YUSUF WANGKO NGANTUNG of International Tax/Tax Compliance and Litigation Services at DDTC. He is an experienced practitioner involved in tax dispute resolution projects, where he Yusuf Wangko Ngantung is the Senior Manager of has represented various multinational companies. He International Tax/Transfer Pricing Services at DDTC. He advises a wide range of domestic and international is an experienced practitioner involved in international clients across industry sectors and provides tax advice tax, dispute resolution, and transfer pricing projects. for private client. Prior to joining DDTC, he worked for Horwath de Zeeuw & de Keizer, the Netherlands, where he was involved in He received his Bachelor’s degree in Fiscal international tax planning projects for both inbound and Administration from the University of Indonesia and outbound investments, European VAT, and taxation on his Master Degree in International Taxation (LL.M. Int. expatriates. Tax) at Vienna University of Economics and Business Administration – Austria, under full scholarship from He received his Bachelor of Law degree (LL.B) in DDTC. In 2011, he attended a course on “Practical Taxation Law (fiscal recht) from the Leiden University, Aspects of International Tax Planning” held by IBFD, in in Leiden, the Netherlands and his Master Degree in Kuala Lumpur, Malaysia. International Taxation (LL.M. Int. Tax) at Vienna University of Economics and Business Administration – Austria, He has passed Principles of International Taxation graduated with honors, under full scholarship from examination paper for Advance Diploma in International DDTC and he was awarded WTS Tax Award, 1st place Taxation from the Chartered Institute of Taxation – for master thesis titled “Tax Treaties and Developing UK, and therefore has been awarded Certificate in Countries” in academic year 2013/2014 at Vienna Principles of International Taxation. He holds a license University of Economics and Business Administration. to practice as a tax attorney by the Tax Court. In 2010, he attended several overseas tax courses held He is also frequently involved as a trainer or a speaker by IBFD, covering the following topics: “Transfer Pricing in various seminars and training in topics regarding Aspects of Business Restructuring” in Singapore, and international taxation, transfer pricing, tax policy, and “Transfer Pricing for Intangibles & Intra-group Financing” Indonesian domestic tax held by DDTC, Directorate in Amsterdam, the Netherlands. Further, in 2011, he General of Taxes, Fiscal Policy Agency, Indonesian attended a course on “Practical Aspects of International Tax Consulting Association (IKPI), PAMA Persada Tax Planning” held by IBFD, in Kuala Lumpur, Malaysia. Nusantara, PT Bio Farma (Persero), PT Archi Indonesia, PT Sarana Multi Infrastruktur (Persero), PT Wijaya Yusuf Wangko Ngantung holds Advanced Diploma Karya (Persero) Tbk, PT Charoen Pokphand Indonesia in International Taxation; Certificate in Principles of Tbk, Christian University of Indonesia, and others. International Taxation; and Certificate of Principles of Corporate and International Taxation (Transfer Pricing) from the Chartered Institute of Taxation, UK and he holds a license to practice as a tax attorney by the Tax Court. He is a lecturer on International Taxation at Master in Accounting Program at the University of Indonesia and Chapter VI of the Transfer Pricing Guidelines; and • latest Developments at OECD on Indirect Taxes & the International VAT/GST Guidelines. She has completed certificate C of Indonesian Tax Consultant Examination and has been licensed to practice as a registered tax consultant. She holds a license to practice as tax attorney by the Tax Court. She is a lecturer on International Taxation at Master in Accounting Program at the University of Indonesia. She is also frequently involved as a trainer or speaker in several tax trainings or seminars, held by DDTC, University of Indonesia, Christian University of Indonesia, Central Bank of Indonesia, Kantor Berita Antara, PT Toyota Astra Motor, PT Total Oil Indonesia, PT Kalbe Farma Tbk, PT Akashi Wahana Indonesia, PT Bahana TCW Investment Management, and others. DEBORAH

Deborah is the Senior Manager of Tax Compliance and Litigation Services at DDTC. She has been involved in transfer pricing study assignments, also significant tax dispute resolution and litigation cases. From her assignments, she has provided clients with satisfactory outcomes. Her main expertise in tax litigation cases includes transfer pricing and business restructuring cases. She received her Bachelor’s degree in Fiscal Administration with cum laude from the University of Indonesia, and her Master’s degree in International Taxation (LL.M. Int. Tax) at Vienna University of Economics and Business Administration – Austria, under full scholarship from DDTC. In 2011, she attended a course on “Basic International Taxation” held by IBFD, in Kuala Lumpur, Malaysia, and a course on “Transfer Pricing Program (Class of 2011)” organized respectively by Inland Revenue Authority of ANGGI TAMBUNAN Singapore, Tax Academy of Singapore, Atax, and the University of New South Wales, Australia, in Singapore. In 2012, she attended seminars and courses held Anggi Padoan Ibrahim Tambunan is the Manager by Vienna University of Economics and Business of Tax Compliance and Litigation Services at DDTC. He Administration, Austria: is an experienced practitioner with particular expertise • The Relevance of Art. 7 OECD MC for the definition in handling tax reviews, and tax dispute resolution of PE; and procedures. He has represented various multinational • Prospects for US Tax Reform. companies involved in mining, forwarding and supply chain, transportation, automotive, aircraft, hospitality, In 2012, she attended seminars and courses held chemical, hotels, heavy equipment and information by Vienna University of Economics and Business technology industry. He is also a regular speaker in Administration and PwC, Austria: topics regarding international taxation and Indonesian • Mandatory and Binding Arbitration in Bilateral and domestic tax in various seminars and trainings held by Multilateral Tax Conventions; DDTC, private institutions, and educational institutions. • The New Politics of Tax Administration; • Capital Gain Taxes on Shares and the Participation He received his Bachelor’s degree in Fiscal Administration Exemption in Europe; and from the University of Indonesia, and Master’s degree in • The Impact of the White Paper for Adequate, Safe Economic Law at the Faculty of Law of the University of and Sustainable Pensions on Treaty Police in Indonesia, under scholarship from DDTC. Europe. He has passed two out of three examination papers In 2013, she attended seminars and courses held for Advance Diploma in International Taxation from by Vienna University of Economics and Business the Chartered Institute of Taxation – UK, including Administration, Austria: Advance International Taxation: Singapore Option; and • Tax Treaty Case Law Around the Globe; Principles of International Taxation, and therefore has • The Chinese Perspective of Global and Domestic been awarded Certificate in Principles of International Tax Policy Issues; and Taxation. Furthermore, he has completed certificate C • GAARs (General Anti-Avoidance Rules) in the of Indonesian Tax Consultant Examination and has been Chinese Tax System. licensed to practice as a registered tax consultant. He holds a license to practice as a tax attorney by the Tax In 2013, she also attended seminars and courses Court. held by Vienna University of Economics and Business Administration and PwC, Austria: In 2011, he attended a course on “Principles of • Treatment of Intangibles for Transfer Pricing International Taxation”, held by IBFD, in Kuala Lumpur, Purposes in the Light of the OECD Update on Malaysia. In 2012, he attended a course on “Practical Aspects of International Tax Planning”, held by IBFD, in Kuala Lumpur, Malaysia. Further in 2013, he also attended a course on “International Taxation of Oil and Gas and Other Mining Activities”, held by IBFD, in Singapore. In 2015, he joined the “Summer Course of International Taxation and Transfer Pricing”, held by the International Tax Center (ITC), Leiden University, the Netherlands.

CINDY KIKHONIA FEBBY

Cindy Kikhonia Febby is the Assistant Manager of Transfer Pricing Services at DDTC. She is an experienced practitioner with particular expertise in transfer pricing for clients in the cosmetic, food, and electronic industries. She received her Bachelor’s degree in Fiscal Administration from the University of Indonesia, and currently she is pursuing her Master’s degree in Strategic Management at VERONICA KUSUMAwaRDANI Gadjah Mada University, under scholarship from DDTC. In 2011, she attended a course on “Principles of Transfer Pricing” held by IBFD, in Kuala Lumpur, Veronica Kusumawardani is the Assistant Manager Malaysia. In 2012, she attended a course on “Taxation of Transfer Pricing Services at DDTC. She is an experienced of Supply Chain Management” held by IBFD in Kuala practitioner with particular expertise in transfer pricing for Lumpur, Malaysia. In 2013, she attended “Summer School clients involved in palm oil, automotive, heavy equipment, of Transfer Pricing Programme” held by the Universidade and mining industries. Católica Portuguesa, in Lisbon, Portugal. On October 10 She received her Bachelor’s degree in Fiscal Administration – 14, 2016 attended a course “Advanced Transfer Pricing from the University of Indonesia, and her Master’s degree Course (Specific Topics)” held by The Institute for Austrian in Accounting at the same university, under scholarship and International Tax Law of WU (Vienna University of from DDTC. Economics and Business), in Vienna, Austria. In 2011, she attended a course on “Principles of Transfer She has passed Principles of Corporate and International Pricing” held by IBFD, in Kuala Lumpur, Malaysia. In 2012, Taxation (Transfer Pricing) examination paper for Advance she attended a course on “Taxation of Supply Chain Diploma from the Chartered Institute of Taxation – UK, Management” held by IBFD in Kuala Lumpur, Malaysia. In and therefore has been awarded Certificate in Principles 2013, she attended “Summer School of Transfer Pricing of Corporate and International Taxation (Transfer Pricing). Program” held by the Universidade Católica Portuguesa, in She passed the exam of Ujian Sertifikasi Konsultan Lisbon, Portugal. She passed the exam of Ujian Sertifikasi Pajak (USKP) A, organized by Indonesian Tax Consulting Konsultan Pajak (USKP) B, organized by Indonesian Tax Association (IKPI) and has been licensed to practice as a Consulting Association (IKPI), and has been licensed to registered tax consultant. She holds license to practice as practice as a registered tax consultant. She holds a license a tax attorney by the Tax Court. to practice as a tax attorney by the Tax Court. She is also frequently involved as a trainer or speaker She is also frequently involved as a trainer or speaker in several tax trainings or seminars, held by DDTC, in several tax trainings or seminars, held by DDTC, governmental institutions, private institutions, and governmental institutions, private institutions, and universities, including Fiscal Policy Agency, Indonesian universities, including PUSDIKLAT Pajak, PT Astra Tax Consulting Association (IKPI), the Institute of Indonesia International Tbk, Christian University of Indonesia, and Chartered Accountant (IAI), PT Astra International Tbk, others. TELKOM Group, PT Mayekawa Indonesia, the University of Indonesia and others. natural ingredients, and coal mining industry. Subsequently, she has also been involved in transfer pricing advisory, audit defense and litigation services She received her Diploma degree in Tax Administration from the University of Indonesia and her Bachelor’s degree in Economics at the same university, under scholarship from DDTC. In 2013, she attended a regular course on “Transfer Pricing” and “International Taxation” held by DDTC, and she passed the exam and holds the certificate of excellence. In 2015, she attended “Global Transfer Pricing Course”, held by Vienna University of Economics and Business Administration, Austria. She has passed Principles of Corporate and International Taxation (Transfer Pricing) examination paper for Advance PRETTY WULANDARI Diploma from the Chartered Institute of Taxation – UK, and therefore has been awarded Certificate in Principles of Corporate and International Taxation (Transfer Pricing). Pretty Wulandari is the Senior Specialist of Transfer Pricing Services at DDTC. She has been involved in transfer She is also involved as a trainer or speaker in transfer pricing services in various industries, such as automotive pricing training or seminar, held by DDTC and University industry, heavy equipment industry, oil and gas industry, of Indonesia. mining industry, pulp and paper industry, stationery industry, biotechnology industry, and cosmetics industry. She received her Bachelor’s degree in Fiscal Administration from the University of Indonesia. In 2013, she attended a regular course on “Transfer Pricing” and “International Taxation” held by DDTC, and she passed the exam and holds the certificate of excellence. In 2015, she attended “Global Transfer Pricing Course”, held by Vienna University of Economics and Business Administration, Austria. In 2014, she has completed certificate A of Indonesian Tax Consultant Examination, organized by Indonesian Tax Consulting Association (IKPI). She has passed Principles of Corporate and International Taxation (Transfer Pricing) examination paper for Advance Diploma from the Chartered Institute of Taxation – UK, and therefore has been awarded Certificate in Principles of Corporate and International Taxation (Transfer Pricing). She is also involved as a trainer or speaker in transfer pricing training or seminar, held by DDTC, Indonesian Tax FLOURESYA LOUSHA Consulting Association (IKPI) and University of Indonesia.

Flouresya Lousha is the Senior Specialist of Transfer Pricing Services at DDTC. She has been involved in transfer pricing study assignments for clients in various industries, such as palm oil, coal, automotive, pulp and paper, chemicals, plastics and natural ingredients. Subsequently, she has also been involved in transfer pricing advisory, audit defense and litigation services. She received her Bachelor Degree in Economics from Tarumanagara University. In 2013, she attended a regular course on “Transfer Pricing” held by DDTC, and she passed the exam and holds the certificate of excellence. She has passed Principles of Corporate and International Taxation (Transfer Pricing) examination paper for Advance Diploma from the Chartered Institute of Taxation – UK, and therefore has been awarded Certificate in Principles of Corporate and International Taxation (Transfer Pricing). DENIA ENDRIANI She is also involved as a trainer in transfer pricing training held by DDTC. Denia Endriani is the Senior Specialist of Transfer Pricing Services at DDTC. She has been involved in transfer pricing study assignments for clients in various industries, such as palm oil, automotive, heavy equipment, plastics, pulp and paper, chemicals, public address system, spices and The art of transfer pricing management“ lies in the continuous, but not frantic, price “ setting and updating. - Frank Schoeneborn -

ADZKA FIKRI FADHILAH

Adzka Fikri Fadhilah is the Senior Specialist of Transfer Pricing Services at DDTC. He has been involved in transfer pricing services in various industries, including apparel, automotive, power transformer, electronic device, heavy equipment, chemical, commodity, food and feed additives. He has also been involved in transfer pricing audit and litigation. He received his Bachelor’s degree in Fiscal Administration from the University of Indonesia. In 2014, he attended a regular course on “Transfer Pricing” held by DDTC, and he passed the exam and holds the certificate of excellence. On October 10 – 14, 2016 he attended a course “Advanced Transfer Pricing Course (Specific Topics)” held by The Institute for Austrian and International Tax Law of WU (Vienna University of Economics and Business), in Vienna, Austria. He is also involved as a trainer or speaker in transfer pricing seminar, held by DDTC, PPSDMS Nurul Fikri and Trisakti University. Menara Satu Sentra Kelapa Gading 6th Floor (Unit #0601 - #0602, #0606) Jl. Bulevar Kelapa Gading LA3 No. 1 Summarecon Kelapa Gading Jakarta 14240