SSJKlopedia - Preparation Master File and Local File - November 2023
According to the Ministry of Finance Regulation (MoF) No. 213/PMK.03/2016, if the Indonesian taxpayer has related party transactions, there is a possibility to prepare Master File and Local File to ensure the related party transactions are arm's length.
The above obligation should be fulfilled if the taxpayer meet certain threshold to prepare the Master File and Local File.
For easy reference, we attach the simple guidance whether the taxpayer has obligation to prepare Master File and Local File.
Tax Update November 2023
According to the Directorate General of Tax Regulation No. PER-29/PJ/2017, the constituent entity (Parent Entity or entity member) or taxpayer that has affiliated transactions are required to submit the Country by Country Report (CbCR) Notification. The CbCR Notification consists of domestic taxpayer information and the statement whether the domestic taxpayer is required to submit CbCR or not.
For the taxpayer with fiscal year January - December, the deadline for submission of CbCR Notification FY2022 is 31 December 2023.
The CbCR Notification should be reported to the DGT by using online system (e-filling), and the DGT will provide the electronic receipt as the prove of submission of CbCR Notification. This electronic receipt should be attached in the Corporate Income Tax Return FY2023 which should be submitted at the end of April 2024 at the latest.
In case the CbCR Notification is not reported and/or attached in the Corporate Income Tax Return, the Tax Office may classify the Corporate Income Tax Return is not completed and reported to the Tax Office.