Indonesia Gives Tax Authority Power to Override Your Intercompany Prices

TL;DR

**## What We Know

Reports suggest that Indonesia's Ministry of Finance issued PMK 172/2023 (Peraturan Menteri Keuangan Nomor 172 Tahun 2023) to overhau**

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The Facts

What We Know

Reports suggest that Indonesia's Ministry of Finance issued PMK 172/2023 (Peraturan Menteri Keuangan Nomor 172 Tahun 2023) to overhaul the country's existing transfer pricing rules — previously governed by PMK 213/2016 — and to bring the framework closer to OECD Transfer Pricing Guidelines.

If confirmed, the regulation makes two structural changes that directly affect foreign-owned businesses operating in Indonesia:

First, it reorganizes how VAT applies to related-party tr

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Next Steps

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