Tujuan Advance Pricing Agreement

12. Oktober 2021

38. The above-mentioned request for unilateral negotiation of the APA must be submitted to the Director General of Taxation, through the Director of International Taxes, no later than 10 (10) working days from the date of written notification that the bilateral APA has given rise to disagreements or has ended. 41. The transfer pricing documentation containing the implementation of the APA Agreement must be available together with the tax return, which shall take place no later than four (four) months after the end of the financial year. The taxpayer is advised to send the digital copy to the e-mail address: map@pajak.go.id as well as another copy for the customer manager. Mutual agreement cases were handled by the Directorate of International Taxation. How long does it normally take to obtain a unilateral APA and a bilateral APA? Direct Perpajakan Internasional Ditjen Pajak (DJP) John Hutagaol. Enter the date on which the above content was correct. Typically, the entire process of applying for a UAPA can take six to eighteen months, while a BAPA application takes three years, as provided for in the tax agreements between Indonesia and the tax treaty partner country. Please describe the process for purchasing an APA, including a brief description of the offer requirements and potential user charges. . „PMK terkait APA dilakukan pembaruan agar sesuai dengan international best practices“, katanya, Kamis (26.3.2020). This content is for Centric subscribers only.

One of the advantages is access to:. 34. DGT expects the taxable person to facilitate an efficient procedure by providing all the information necessary to properly examine the application and reach an agreement in good time. This also covers the company`s cooperation to ensure that the formal ABS agreement and all related procedural documents are concluded shortly after the conclusion of the transfer pricing method and/or in a bilateral or multilateral process after the conclusion of agreements with contracting parties. 27. The examination of the application should be a cooperation procedure in which transfer pricing issues are discussed openly and access to relevant information and supporting documents is made available. The taxpayer makes available to the DGT information known (or should be known) to the taxable person which may have an impact on the outcome of the APA agreement without having to wait for a request from the DGT. The lack of cooperation in this respect may lead the DGT to refuse to continue examining the application.

30. Bilateral ABS are governed by the POP Protocol. The taxpayer will not participate in the BAPA negotiations unless the two CAs mutually agree that the taxpayer may be present during the hearing to explain the issues under discussion. . . .

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