Transfer Pricing / All

The tax authorities are paying special attention to transfer pricing issues.

The law that enacted the transfer pricing rules was passed year end 2013and came into effect 1 January 2014.

Indonesian transfer pricing has seen a flurry of activity since 2009 with theintroduction of a number of transfer pricing-related regulations and a concurrentdrive by the Indonesian Tax Office (ITO) to enforce them.

Transfer pricing legislation was introduced as part of the 2010 Finance Act,effective for accounting periods on or after 1 January 2011

The transfer pricing regulations require companies to list all international transactions on the corporate tax return (Form 1385) and to declare that the transactions were conducted according to “market conditions”.

At this stage, there are no official observations from the Italian Tax Authorities on the Base Erosion and Profit Shifting (BEPS) initiative.

The 2012 Tax Reform does not include major changes in transfer pricing areas, although it has some important changes in tax investigation procedures in general

As of 1 January 2013 the legislation requires a written transfer pricing study with specific information included, if a taxpayer’s annual net turnover exceeds 1.43 million Euros (EUR) and intra-group transactions undertaken exceed EUR14,300.