Language of TP documents

Dokumen TP boleh dalam bahasa Inggris?

The situation

Documentation must be in Indonesian. Companies with permission to keep books in English still need an Indonesian translation.

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
  • Art 28, Law 6/1983 on General Provisions and Tax Procedures (KUP Law), as last amended by Law 6/2023: Businesses and companies must keep books in Indonesia, in Indonesian and in rupiah unless permitted otherwise; small individuals may keep records instead

What it means for you

Group master files are often in English; prepare an Indonesian version. Check translation quality. The DJP can treat a file it cannot read as not provided, which weakens your position in audit. Budget translation time inside the 4 month window.

What to do

  1. Get the group master file.
  2. Translate it.
  3. Prepare the local file in Indonesian.
  4. Keep both versions.

English only files can be rejected.

We can do this for youTransfer pricing documentation: master file, local file, summary with the annual return and CbCR: IDR 45.000.000

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