Advance Pricing Agreement

An Advance Pricing Agreement (APA) is an agreement between a taxpayer and tax authority (or multiple tax authorities). this agreement establishes the transfer pricing methodology to be used for a specific set of related-party transactions for a certain period of time in the future. The purpose of an APA is to provide certainty and predictability … Read more

Transfer Pricing

Transfer Pricing

Transfer pricing refers to the pricing of goods, services, and intangible assets that are transferred between different entities within a multinational enterprise. It is a key issue in taxation because it can affect the allocation of profits between different jurisdictions and therefore impact the tax liabilities of each entity involved. For example, if a subsidiary … Read more

Introduction of Tax Treaty

The term used for tax treaties in Indonesia is “Perjanjian Penghindaran Pajak Berganda” (P3B) In English, it is known as a double taxation avoidance agreement or a tax treaty. The P3B is an agreement between Indonesia and another country that is designed to eliminate double taxation of income and to prevent tax evasion. These agreements … Read more

Permanent Establishment

In taxation, a permanent establishment (PE) is a fixed place of business through which a business carries out its activities, either wholly or partially. The concept of permanent establishment is important for determining the tax liability of a business in a foreign country. When a company operates in a foreign country through a permanent establishment, … Read more

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