Transfer Pricing and International Tax

Advanced Pricing Agreement

IDSP assists companies in securing unilateral, bilateral, or multilateral Advance Pricing Agreements (APAs) with the tax authorities to obtain agreement on transfer pricing methods and ensure certainty in future transactions.

Our team supports the entire process — from preparing the required documentation and analysis to coordinating discussions and managing submissions until the APA decision is issued. We ensure your application is well-prepared, compliant, and strategically aligned to provide long-term tax certainty and reduce potential disputes.

Mutual Agreement Procedure

IDSP provides professional assistance in resolving cross-border tax disputes through the Mutual Agreement Procedure (MAP).

We assist in preparing position papers, coordinating with competent authorities, and managing communications throughout the negotiation process. Our team ensures your case is clearly presented, technically sound, and effectively managed to achieve a fair resolution under the applicable tax treaties.

Transfer Pricing Dispute Resolution

IDSP provides professional assistance in resolving transfer pricing disputes.

We support clients in addressing transfer pricing issues during audits and dispute processes, ensuring that your company’s position is clearly presented, technically sound, and strategically managed to achieve a fair and sustainable outcome.

Transfer Pricing Documentation

IDSP assists companies in preparing transfer pricing documentation that complies with Indonesian tax regulations, the OECD Transfer Pricing Guidelines, and the UN Practical Manual on Transfer Pricing.

Our team conducts detailed functional analyses, benchmarking studies, and prepares the required Master File, Local File, and Country-by-Country Report (CbCR). We ensure your documentation is accurate, defensible, and aligned with the arm’s length principle to support full compliance and effective risk management.