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TP summary in the annual return

Ringkasan dokumen TP dilampirkan di SPT badan?

The situation

Yes. A summary of the master file and local file is attached to the corporate annual return.

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 3, Law 6/1983 on General Provisions and Tax Procedures (KUP Law), as last amended by Law 6/2023: Returns are due 20 days after the month for most monthly returns, end of the next month for VAT, 3 months after year end for individuals and 4 months for companies; annual returns can be extended by up to 2 months

What it means for you

The summary lists related parties, transactions and methods. Coretax has a place for it in the return. Keep the full files ready. Fill it in after the full files exist, so numbers match. The DJP uses the summary to choose audit targets.

What to do

  1. Prepare the files first.
  2. Fill in the summary.
  3. Attach to the return.
  4. Keep the full files.

A summary that does not match the full files invites questions.

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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