Flash Alert – Notification and Country-by-Country-Report for Fiscal Year 2019

Director General of Taxes has issued regulation No. 29/PJ/2017 dated 29 December 2017 (PER 29) regarding management procedures of Country-by-Country Report (CbCR) which is further provisions of regulation of Minister of Finance No. 213/PMK.03/2016 dated 30 December 2016 (PMK-213).

Submission of Notification (notification submitted by Taxpayer to the Directorate General of Taxes stating that the Taxpayer has an obligation or does not have the obligation to submit a CbCR) for fiscal year 2019 no later than 12 (twelve) months after the end of Parent Entity’s fiscal year, through DJP Online or manually in the case of DGT Online cannot be used.

The notification must be submitted to the Directorate General of Taxes at the latest by 31 December 2020 for fiscal year 2019 (for the year ended 31 December 2019).

In the event of the Taxpayer has the obligation to submit the CbCR as stipulated in PMK-213 and PER-29, the Taxpayer has to submit the CbCR that is attached with the working paper of the CbCR along with the submission of the Notification.

The CbCR must be conducted based on available data and information until the end of the Taxpayer’s or Parent Entity’s fiscal year referring to PMK-213 and PER-29. In the event of the Taxpayer does not meet this requirement, the Taxpayer is considered not applying the Arm’s Length Principle (the principle of fairness and business normality).

Receipt from the Directorate General of Taxes for submission of the CbCR and/or Notification must be attached to the Annual Corporate Income Tax Return for fiscal year 2020.

References :

  • Regulation of Director General of Taxes No. 29/PJ/2017 dated 29 December 2017 (“PER-29”) regarding Management Procedures of CbCR.
  • Regulation of Minister of Finance No. 213/PMK.03/2016 dated 30 December 2016 regarding types of additional documents and/or information that must be retained by the Taxpayer conducting transactions with related party and its management procedures.

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