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Transfer Pricing Advisory in Indonesia

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Aiming at protecting their tax revenues, tax authorities across the globe are developing and implementing strict regulations. The main concern of the tax authorities is related to cross-border business transactions — whether they have been established in accordance with the worldwide-accepted arm’s length principle and if the transactions are documented according to domestic tax rules.

Overview of Transfer Pricing in Indonesia

Overview of Transfer Pricing in Indonesia

Since transfer pricing (TP) can be used to transfer assets and income between jurisdictions, all with favourable tax rates, tax authorities have now considered it a significant issue. With that being said, Indonesian tax authorities attempt to tackle the challenge by implementing detailed TP regulations and complex documentation requirements, among others.

Related parties that fail to comply with the TP regulations and cannot satisfy the Indonesian documentation requirements can suffer from severe penalties. Nevertheless, when related parties can understand that TP is a continuous process, they will eventually be able to minimise risks related to taxes in Indonesia.

Cekindo’s Transfer Pricing Advisory Services in Indonesia

Your business model is the key to determine your TP setting. Our TP advisory services are marked by the objective to support your business needs, while at the same time are designed to comply with the statutory requirements in Indonesia and international practices.

Based on our extensive experience in transfer pricing, our team can provide you with the following services:

  • Determination of arm’s length price range in respect of the proposed related party transactions such as cost plus mark-up analysis and arm’s length net margin range.
  • Review of existing value chain to identify any areas of risk and opportunities to improve existing TP policies.
  • Review of inter-company agreements to ensure that the same is compliant from TP perspective.
  • Royalty benchmarking to determine the arm’s length royalty payout for use of IP keeping in view the functional profile of the transacting entities.
  • Management cross-charge documentation, including benefit analysis and methodology for arm’s length cross-charge.


Nipun Arora

Nipun Arora
Director, Transfer Pricing Practice

Nipun is a Chartered Accountant from India and leads the Transfer Pricing practice at In.Corp Global Pte Ltd in Singapore. He has worked with Big Four accounting firms throughout his career and has accumulated more than 13 years of experience in Transfer Pricing (TP) providing advisory services to medium and large sized multinational corporations in the Automotive, FMCG, Retail, Telecom and Luxury goods sector. Nipun has been involved in several litigation matters involving complex TP issues and has assisted Senior Counsels in India upto the High Court stage. He has also been involved in assisting clients in preparing year end Transfer Pricing documentations ensuring that the Transfer Pricing policies are in agreement with the arm’s length principles and the BEPS Action Plans. He has also worked on several large TP Due Diligence mandates.


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Selected Testimonials

  • logo Ohmnia

    As a new business in Indonesia, we started consulting with multiple law firms but quickly narrowed down to only Cekindo. Cekindo was recommended as one of the top firms by multiple sources in the business community. The staff at Cekindo was very responsive to our needs as a new business. The team provided consultancy and assisted our startup firm with initial business setup, licenses and permits, HR/recruitment and market research. One year since our establishment, we still consider Cekindo as our partner.

    PT Ohmnia Tenaga Surya
  • Jan Pilar - Hydropol

    When we intended to enter the Indonesian market back in 2013/14, Cekindo helped us to understand the possibilites and options for business presence in Indonesia through legal advice & also advisory on how to arrange for ownership. Furthermore, Cekindo also provides us with a range of fully professional and reliable accounting & tax services for our representative office in Indonesia. In the world of digital & virtual economy like today, it is an essential prerequisite to have the most reliable business partner like Cekindo.

    Jan Pilař
  • Sagar Datar - Bristlecone

    A huge gratitude to Cekindo, particularly its visa team, for handling our visa cases. During our visa applications, Cekindo was extremely helpful not only in facilitating all of our visa requirements but also in clarifying our queries/doubts. I would like to take this opportunity to acknowledge and appreciate the good work of Cekindo’s visa team.

    Sagar Datar
  • Matthias Coessens - Empyrean

    When I was looking for a reliable partner who could help with company registration, payroll, taxes and working permit in Indonesia, Cekindo’s domain knowledge and clear communication astonished. Firstly, we decided to pursue cooperation with Cekindo in terms of company registration, but they also assisted me in obtaining the necessary working permits and visas (KITAS), and we use their payroll and tax reporting services until now.

    Matthias Coessens
    Product Director at Empyrean Solutions Apac
  • Ivana Bartonkova

    Cekindo handled business visa for our new colleague promptly and made the start of our company in Vietnam easier and faster. I particularly enjoyed communication with the consultant, who advised the best solution for us and was all the time available to answer any questions. She made sure that all the documents were collected and prepared on time and we got great support during the whole process. Thank you Cekindo and I hope to cooperate again in the near future!

    Ivana Bartonkova
    Marketing and HR director of Port Cities Vietnam
  • Phyto CZ Sro

    Cekindo assisted us with a selection of our local distributor in Indonesia and organised several meeting in Jakarta. Their assistance enabled us to meet our potential local partners and choose the best distributor conveniently. The decision to cooperate with Cekindo was based on a recommendation from our prominent partner in Bali and we cannot be more grateful. Cekindo’s systematic work, active communication, thoroughness and professionalism was exceptional.

    Ing. Václav Tomek
    Phyto CZ Sro
  • Vivek Singh Rathaur

    Cekindo initially helped us with setting up our business structure in Indonesia and getting us all due licenses and approvals. Currently, Cekindo is associated with us as our business partner in Indonesia by providing a face to our name and handling various business activities on our behalf. Without their help, we would be lost in keeping up with regulatory requirements and being a compliant company in Indonesia.

    Vivek S.Rathaur
    Vega Industries
  • akvo - cekindo

    Thanks to Cekindo and its one-stop market entry solutions, we could start exploring the Indonesian market. Cekindo’s broad portfolio of services included a formal process of our representative office registration, consultations regarding proper legal set-up and even working permit and visa applications. Cekindo’s extensive knowledge of the latest developments and legal requirements allowed us to focus on more operational matters and to build a local team in Indonesia.

    Peter van der Linde
    Co-founder / Director strategy & solutions, Akvo Pte Ltd
  • morning-star-cekindo

    After extensive research online, I reached out to several companies including Cekindo. Cekindo’s info package and summary of services were by far the most thorough and professional and their pricing was competitive and reasonable. Cekindo’s sound knowledge of all administrative requirements gave me the confidence that my company incorporation of 100% foreign owned export company was being executed correctly and legally.

    Kingsley Fiegert
    Director, Morning Star Investments (WA) Pty Ltd
  • Jason Peter Stevens

    With knowledgable team, Cekindo helped me make the whole process of company registration and product registration of health and beauty products in Indonesia less confusing and seamless at the same time. They have always been swift in response and hands-on at every email, never leaving me wondering or worried. As far as I am concerned, they go above and beyond the call of duty. They will most certainly be my long-term partner moving forward into the years to come. Thank you Cekindo!

    Jason Peter Stevens
    Group CEO, Studio XII Pte Ltd