Indonesia has adopted the OECD BEPS Action 13 guidelines related to Transfer Pricing Documentation and Country-by-Country Reporting through PMK213/PMK.04/2016 and PMK 172 Year 2023 (“MoFR”(. This MoFR has brought significant changes to the concepts and
methods previously established, implementing a three-tiered framework for Transfer Pricing Documentation: Master File, Local File, and Country-by Country Report (CbCR(. It also outlines the essential information required and sets a submission deadline for each fiscal year, which
must occur within four months following the end of the tax year.

Furthermore, a key change involves the ex-ante analysis, mandating that taxpayers perform an arm’s length analysis using the information available at the time of the transaction. Consequently, the documentation must demonstrate that the pricing strategies employed by taxpayers for transactions with related parties are in line with arm’s length principles. This requirement differs from the ex-post analysis typically applied in many other jurisdictions