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  • Transfer pricing controversy and litigation

Transfer pricing controversy and litigation

Your Concerns

  • Local avenue:

Assistance with transfer pricing audit, filing tax objection and filing tax appeal to the tax court.

  • International avenue:

Assistance with Mutual Agreement Procedure for transaction with a tax treaty country.

  • Get legal certainty for future related party transactions through planning and/or Advance Pricing Agreement (“APA”).

How BDO Can Help

Tax authorities are increasingly challenging the pricing of related party transactions. BDO Indonesia’s Transfer Pricing professionals can help you in navigating your company through any such disputes. In the event of an audit or tax authority enquiry, we can help you develop a defensive strategy based on relevant local and international legislation, guidance and practice.

Our experienced team is able to communicate and negotiate with tax authorities on your behalf and, where there has been a transfer pricing adjustment, we will successfully guide you through the Mutual Agreement Procedure under relevant tax treaties to avoid double taxation or to negotiate APAs.

Our transfer pricing dispute resolution services would cover:

  • Advising you on how to best present data/information to the ITO or tax court judges.
  • Assisting you to put forward technical arguments that would strengthen your transfer pricing position.
  • Guiding you in every step of the process and advising your rights as a taxpayer.
  • Sharing with you our past experience and collaborating with you to develop an effective but practical defence strategy.

Advance Pricing Agreement

  • Assisting with the pre-lodgement phase.
  • Assisting with the preparation of the planning document.
  • Assisting with the preparation of the
  • Advance Pricing Agreement Application.
  • Assisting you in the discussions with the tax authorities.


BDO is among the largest global professional firms and has more than 250 transfer pricing professionals in more than 158 countries that operate through more than 1,400 offices across the globe. When it comes to transfer pricing, a strong global network will ensure that all solutions are delivered with a multi-jurisdiction mindset – a balancing act on taking into consideration the interests of the tax authorities in jurisdictions involved in your cross-border transactions. This places BDO in a position to provide transfer pricing support to our clients wherever their business takes them.