Types of Transfer Pricing Documentation are regulated through Article 2 paragraph (1) of the Minister of Finance Regulation number 213/PMK.03/2016 concerning Types of Documents And/Or Additional Information That Must Be Retained By Taxpayers Engaging In Transactions With Parties Having Special Relationships, And Management Procedures. It consists of 3 types of TP Documentation:

Master file,
Local file, and
CbCR (Country-by-Country Report).

Points 1 and 2 have been explained in the previous article.

This article will discuss the Country-by-Country Report (CbCR) in TP Documentation.

Regulated through Article 2 paragraph (4) of the Minister of Finance Regulation number 213/PMK.03/2016, it is stipulated that:

In the case where a domestic taxpayer is a member of a business group and the parent entity of the business group is a foreign tax subject, the domestic taxpayer must submit a country-by-country report as referred to in paragraph (1) letter c, provided that the country or jurisdiction where the parent entity is domiciled:

a. does not require the submission of a country-by-country report;
b. does not have an agreement with the Indonesian government regarding the exchange of tax information; or
c. has an agreement with the Indonesian government regarding the exchange of tax information, but the country-by-country report cannot be obtained by the Indonesian government from that country or jurisdiction.