WHO WE ARE
TRUE PARTNERS IN TEAM WORK
Established in Jakarta, Indonesia in 2009, PreciousNine is present to help you solve your tax and business problems.
With more than 15-year working experience in the area, our professionals understand quite well why and how to factor in tax when you make business decisions. Good tax planning will protect you from surprise tax assessments which may lead to serious damages to your business. A review of your past deals will reveal the pitfalls that may attract potential tax assessments.
We quite understand how to deal with such problems and are committed to share our experience and expertise to solve your tax and business problems. Trust and teamwork is key to any effective solutions. We will therefore work with you as true partners
“A big part of financial freedom is having your heart and mind free from worry about the what-ifs of life.”
– Suze Orman
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Transfer pricing under PMK 172/2023
Aiming for fair pricing with outright TPD
Tax relies on market forces for the pricing of virtually all types of business transactions. Market mechanism is believed to work well with transactions between independent parties: fair outcome is just taken for granted. Not so with transactions between parties of the same business group, deemed as being automatically consumed with a special relationship.
Minister of Finance (MOF) regulation Number PMK 172/2023 regarding transfer pricing (PMK 172) issued in late last year and took effect last month, like many other transfer pricing regulations, notionally aims to tackle the potential problem of unfair (non-arm’s length) pricing resulting from the presence of a special relationship in transactions between parties of the same group (affiliated transactions). This is dealt with from three fronts: outright transfer pricing documentation (TPD), mutual assistance procedure (MAP), and advance pricing agreement (APA).