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Aside from being a challenge for multinational companies, the Covid-19 pandemic situation has also changed transfer pricing practices. This situation is relevant with the obligation of taxpayers conducting affiliated transactions to complete transfer pricing documentation FY 2021 and prepare transfer pricing documentation FY 2022 using ex-ante approach.
To prevent transfer pricing disputes, taxpayers also have the option to apply for an Advance Pricing Agreement (APA) mechanism. On the other hand, it is interesting to discuss the transfer pricing aspect in the update of the domestic and global tax landscape such as the Harmonized Taxation Law (UU HPP) and the OECD Two Pillar Solution addressing digital economy taxation.
Darussalam, S.E., Ak., CA., M.Si., LL.M Int. Tax.
Managing Partner DDTC
Adinda Nur Larasati, S.E., B.Comm
Human Resource Business Partner