MUTUAL AGREEMENT PROCEDURE
If you face a tax treaty-related dispute with the DGT, you may consider Mutual Agreement Procedure (MAP) for a resolution.
For sure, this is not an alternative to the objection or litigation you may have in place for the same case: both can go in parallel.
Your transfer pricing dispute is a potential candidate. But you can also bring other disputes as long as they pertain to a tax treaty. These include, for instance, differing interpretation of the tax treaty provision leading to a WHT 26 dispute.
PreciousNine assists you in pursuing MAP. Our service includes assessing your case, preparing and/or reviewing supporting documents, and accompanying or representing you in discussions or meeting with the DGT or the Indonesian Competent Authority.