Indonesia’s head of transfer pricing issues audit warning

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Indonesia’s head of transfer pricing issues audit warning

Indonesia’s head of transfer pricing has told a seminar of tax professionals the criteria used for initiating an audit, amid increased scrutiny from the country’s tax authorities.

Bapak Edward Hamonangan Sianipar, the section head of the transfer pricing unit at the Indonesian Directorate General of Taxation (ITO), told the audience that there are five situations that are likely to lead to an audit.

Pak Edward explained that the declaration of consistent losses, payment of minimal taxes, significant related party transactions, variations from commercial norms, and a lack of appropriate supporting documentation would all likely lead to an audit.

It was also explained that the ITO has over 1,000 dedicated staff, of which about 60% are auditors. Therefore, the risk of being audited is very real for companies characterised by any of the above situations.

Pak Edward also mentioned that the ITO plans to select 10 taxpayers for review from each tax office, starting with the large and medium taxpayers offices and those dealing with foreign investors. Out of these companies reviewed, the ITO has set a target of four to be selected for a full transfer pricing audit.

“To reduce the risk of reviews and audits mentioned by the ITO, companies should implement practices which diminish the number of key audit exposure factors or prepare complete documentation to prove the arm's-length nature of their related party transactions,” said Steven Tseng, China & Asia-Pacific transfer pricing leader at KPMG.

The conference concluded by stating that taxpayers should take extra precautions to prevent an audit.

It was outlined that being able to demonstrate where differences in facts justify different price, demonstrating the ‘willingness to pay’ concept for services, providing rigorous determination of cost bases and allocations, and providing complete documentation during an audit all will help in reducing the risk of an audit.

This news comes after the ITO asked taxpayers to attend a training seminar conducted by its transfer pricing team.



more across site & shared bottom lb ros

More from across our site

Meanwhile, one expert highlights the importance of separating Venezuela’s tax authority from direct political control after ‘lost decades and isolation’
With PMK 108, Indonesia has upgraded its tax transparency regime for the digital era, focusing on data quality, governance, and cross border exchange rather than expanding regulatory reach
In a popular LinkedIn post, Jeremie Beitel encouraged firms to invest in junior talent even if it doesn’t lead to their loyalty, though recruiters offered ITR a mixed assessment
Advisers who do not register for the new regime in time could be prevented from interacting with HMRC, the tax authority said
Valid pillar two objectives are still intact after the side-by-side agreement, but whether the framework is now settled is ‘a $64,000 question’, Morrison Foerster’s tax chair told ITR
Ian Halligan previously led Baker Tilly’s international tax services in the US
Exclusive ITR data emphasises that DEI does not affect in-house buying decisions – and it’s nothing to do with the US president
The firms made senior hires in Los Angeles and Cleveland respectively; in other news, South Korea reported an 11% rise in tax income, fuelled by a corporation tax boom
The ‘deeply flawed’ report is attempting to derail UN tax convention debates, the Tax Justice Network’s CEO said
Salim Rahim, a TP specialist, had been a partner at Baker McKenzie since 2010
Gift this article