Transfer Pricing Documentation

For companies with material related-party transactions, transfer-pricing (TP) documentation isn't optional — it's mandatory under PMK 213/2016 and subsequent updates. Good TP documentation isn't just compliance; it's the first line of defence when related-party transactions are audited.

The three-tier documentation

Master File

The global group profile — organisational structure, key intangibles, financing model, and the group TP policy. Drafted in English and aligned with OECD practice.

Local File

The Indonesian entity profile — functional analysis, comparability analysis, TP method selection (CUP, RPM, CPM, TNMM, or PSM), and benchmarking from recognised comparator databases. This is the document auditors ask for most often.

CbCR — Country-by-Country Reporting

For groups with consolidated revenue above IDR 11 trillion, CbCR is an annual obligation. We prepare the report and coordinate CbCR notifications across the relevant jurisdictions.

Scope of a TP engagement

• Diagnostic review of material related-party transactions and risk-area identification.
• Database benchmarking using Bloomberg, Compustat, or OSIRIS.
• Drafting of Master File, Local File, and CbCR.
• TP Policy document implementable within the current year.
• Defence file for TP audits, including bilateral APA analysis where relevant.

Why quality matters

TP documentation that ticks the boxes without real depth becomes a liability under audit. IBU produces documentation that actually defends — with benchmarking that documents its method and functional analysis reflecting your real operations, not a template used for every client.