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

If Trump continues to poke the world’s ‘middle powers’ with a stick, he shouldn’t be surprised when they retaliate
The Netherlands-based bank was described as an ‘exemplar of total transparency’; in other news, Kirkland & Ellis made a senior tax hire in Dallas
Zion Adeoye, a tax specialist, had been suspended from the African law firm since October over misconduct allegations
The deal establishes Ryan’s property tax presence in Scotland and expands its ability to serve clients with complex commercial property portfolios across the UK, the firm said
Trump announced he will cut tariffs after India agreed to stop buying Russian oil; in other news, more than 300 delegates gathered at the OECD to discuss VAT fraud prevention
Taxpayers should support the MAP process by sharing accurate information early on and maintaining open communication with the competent authorities, the OECD also said
The Fortune 150 energy multinational is among more than 12 companies participating in the initiative, which ‘helps tax teams put generative AI to work’
The ruling excludes vacation and business development days from service PE calculations and confirms virtual services from abroad don’t count, potentially reshaping compliance for multinationals
User-friendly digital tax filing systems, transformative AI deployment, and the continued proliferation of DSTs will define 2026, writes Ascoria’s Neil Kelley
Case workers are ‘still not great’ but are making fewer enquiries, making the right decision more often and are more open to calls, ITR has heard
Gift this article