Country by country report for a local group

The situation

CbCR applies to groups with consolidated revenue of at least IDR 11 trillion for an Indonesian parent. Foreign parents follow their own country threshold, often EUR 750 million.

The law

• PMK 172/2023 on the arm's length principle: Master file and local file if prior year revenue is over IDR 50 billion, tangible related party deals over IDR 20 billion, other related party deals over IDR 5 billion, or a related party in a lower tax country

What it means for you

Constituent entities in Indonesia may need to notify who files the CbCR. Check your group status each year. A foreign parent group usually files in its home country, and the Indonesian entity gives a notification. Check which entity the group names as filer.

What to do

1. Check group revenue.
2. Identify the filing entity.
3. Notify as required.
4. File within 12 months.

Missing the notice is a common gap.

Related

• TP summary in the annual return
• Advance pricing agreement option
• Deadline to produce the local file
• Language of TP documents
• Management fees paid to head office
• Transfer pricing adjustment treated as dividend