02 — International Tax & PMA
Understand Indonesian tax obligations, cross-border implications, and potential tax exposure with structured advisory tailored to your business context.
Client situations
Service fees, royalties, interest, and dividends paid offshore raise withholding tax, VAT, and deductibility questions that need consistent treatment.
Reduced treaty rates depend on procedural requirements and on the recipient meeting substance and beneficial ownership conditions.
Investment structure, financing, and operating model choices have tax consequences for the Indonesian entity and the wider group.
Headquarters need Indonesian tax matters explained clearly in English, with exposure and options presented in a consistent format.
Scope of assistance
Engagement process
Map the group structure, Indonesian operations, and cross-border flows in scope.
Review contracts, payment records, treaty documentation, and filings against applicable rules.
Explain treatment, exposure, and options in writing for local and regional decision-makers.
Assist with documentation, agreed changes, and ongoing questions as transactions evolve.
Considerations
Treaty benefits in Indonesia are subject to procedural requirements set by the Directorate General of Taxes (including PER-25/PJ/2018) and to anti-abuse tests. Missing documentation can result in domestic rates being applied.
Activities of foreign personnel or agents in Indonesia may create a permanent establishment. The applicable treaty and domestic rules (including PMK-35/PMK.03/2019) should be considered before activities begin.
Shareholder loans are subject to debt-to-equity limits (PMK-169/PMK.010/2015) and to arm's length requirements for related-party interest.
Summary for general information only. Regulations are applied to the specific facts of each engagement.
How we present exposure to management
Impact
FAQ
Yes. Deliverables can be prepared in English and we can join calls with regional finance or tax teams, as agreed in the engagement scope.
Ideally before new intercompany agreements are signed or new payment types begin, and periodically as part of year-end preparation. Earlier review allows documentation to be put in place before payments are made.
Yes. Transfer pricing is closely linked to cross-border advisory and is covered under our Transfer Pricing practice. We coordinate the two where both are in scope.
Related
Risk assessment, documentation, and benchmarking for related-party transactions under Indonesian transfer pricing rules.
Explore Transfer PricingStructured review, planning, and written opinions that help management understand tax positions before material decisions are made.
Explore Tax AdvisoryArticle · International Tax & PMA
Service fees, royalties, and interest paid to foreign affiliates raise withholding, VAT, and deductibility questions that are easier to resolve before payments begin.
PrimeTax Editorial Team
Article · Transfer Pricing
Documentation is more than a compliance file. It should explain how the business creates value and why related-party prices are reasonable.
PrimeTax Editorial Team
Share the context of your matter. We will propose a scope and approach for an initial discussion.
