Indonesia Transfer Pricing Documentation Requirements
Indonesia requires a Master File and Local File where a taxpayer exceeds revenue or transaction thresholds, or where a related party sits in a jurisdiction with a lower tax rate. Documentation must be based on data available when the transaction occurred, and a fresh benchmarking search is required every year.
Requirements at a glance
| Requirement | Threshold | Deadline | Deadline type | Language | Penalty |
|---|---|---|---|---|---|
Master File Required | Prior-year revenue > IDR 50bn, tangible transactions > IDR 20bn, or intangibles > IDR 5bn (or a lower-tax related party) | By the return filing date | Preparation deadline The documentation must exist by the date shown and is produced only when the tax authority requests it. Once requested, it must be provided within 30 days. | ID | Yes (fine plus interest; review without regard to undelivered files) |
Local File Required | Same thresholds as the Master File | By the return filing date | Preparation deadline The documentation must exist by the date shown and is produced only when the tax authority requests it. Once requested, it must be provided within 30 days. | ID | Yes (fine plus interest; review without regard to undelivered files) |
CbC report Required | Group revenue ≥ EUR 750m | 12 months after fiscal year-end | Submission deadline The Country-by-Country report is filed by the group's ultimate parent entity; a local notification identifying the reporting entity is filed separately. | — | Yes |
Calculate your exact Indonesia deadline
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Scope of the documentation obligation
A Master File and Local File must be prepared where, in the previous fiscal year, the taxpayer had gross revenue above IDR 50 billion, tangible-goods related-party transactions above IDR 20 billion, or intangible related-party transactions above IDR 5 billion. The obligation also arises, independently of those thresholds, where in the current year any related party was in a tax jurisdiction with a rate lower than the Indonesian corporate rate. The documentation is held available by the return filing date and produced within 30 days of a request, and a summary declaration is attached to the corporate income tax return.
Distinctive features of the Indonesian regime
Two features distinguish the Indonesian regime. The first is the lower-tax-jurisdiction trigger: a taxpayer that would otherwise fall below the size thresholds is still drawn into the full documentation obligation if it transacts with a related party in a lower-tax jurisdiction, which targets profit-shifting structures directly. The second is the consequence of late delivery. Where the Master File or Local File is not delivered on time, the tax office may proceed to review the related-party transactions without regard to the files, alongside a fine for the declaration failure and interest on any underpayment, so the documentation effectively forfeits its evidential value if it is produced late. There is no safe harbour.
Benchmarking and comparables
Comparables in the same location as the tested party are preferred. A single-year analysis is preferred, with multi-year analyses accepted where specific support exists for their use. A fresh benchmarking search is required every year, reflecting the rule that the documentation must be organised on the basis of the data and information available at the time the related-party transaction is conducted. There is no separate transfer pricing limitation period: the general rule applies, allowing an audit and assessment within five years of the relevant year, extended to ten years in defined cases.
Frequently asked questions
Can a smaller Indonesian taxpayer still be caught by the documentation rules?
Yes. Even below the revenue and transaction thresholds, the full Master File and Local File obligation applies where a related party is in a tax jurisdiction with a rate lower than the Indonesian corporate rate.
What happens if Indonesian documentation is delivered late?
The tax office may proceed to review the related-party transactions without regard to the Master File or Local File, alongside a fine for the declaration failure and interest on any underpayment, so late documentation loses its evidential value.
This guide is an informational research aid prepared by Comp-Press and is not tax or legal advice. Transfer pricing rules change; verify current requirements before relying on them for filing.