The Ministry of Finance in Indonesia has released regulation No. 7/PMK.03/2015 (PMK-07) on the implementation of advanced pricing agreements (APAs). The guidance on the processes is provided in PMK-07. PMK-07 states that the Directorate General of Taxation (DGT) should use to implement APAs as well as changes to prior APA-related criteria released by the DGT.
PMK-07 also includes the following requirements as part of the refinement process:
- a requirement that taxpayer’s can only submit an APA application when they have been operating or conducting business in Indonesia for at least 3 years;
- a requirement that an APA can cover only 3 fiscal years for a unilateral APA or 4 fiscal years for a bilateral APA;
- increased information to be included in pre-filing requirements;
- a requirement that the pre-filing application must be submitted at least 6 months before the start of the fiscal year that is to be covered by the APA, and the formal APA application must be submitted no later than 1 month before the fiscal year that is to be covered by the APA;
- guidance on the processes for APA renewal; and
- guidance on what the annual compliance requirements are for an agreed APA.
