Page 2 - Newsletter (An Update on CbC Reporting Regulations in Indonesia)
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DDTC Tax Newsletter 02  I  Jan 2018                                                        Page 2 of 2


          An Update on CbC Reporting Regulations in Indonesia


          Notification obligation                              release a  list of  treaty partner countries that have a treaty

                                                               in place containing an exchange of information clause,
            Regardless whether a domestic taxpayer is required to   qualifying competent authority agreements (QCAA), and
          submit a CbC Report or not, all taxpayers who are member   have QCAA but CbC Reports are unobtainable by the DGT.
          entities of a group or have related party transactions, are
                                                                  Upon the announcement of the list of such countries,
          obliged to submit a notification concerning CbC Report
                                                               domestic taxpayers delegated with  the  CbC Report
          to the DGT.
                                                               obligation has 3 months to submit CbC Report. If within
            The  Notification  in  question  contains  a  statement   that period, the taxpayer fails to submit a CbC Report, the
          about  the identity along  with  the jurisdiction  of the   Directorate General of Taxes shall send a formal request
          particular member entity of the group that is to conduct   letter to said taxpayer, and grant a 30-day extension since
          the CbC  Report. This  is intended  to facilitate the DGT   the date of the request letter.
          in requesting CbC  Reports  through  cross-border
          information exchange mechanism.                      XML Schema Electronic Format

            Having  submitted  the  notification,  the  taxpayer
                                                                  PER-29 provides that the submission of CbC Reports
          will be given a receipt that can be used as a substitute
                                                               must be conducted  electronically i.e. with Extensible
          for CbC Report to be attached to the Annual Corporate
                                                               Markup Language (XML). In line with the international
          Income Tax Return. Said notification should be submitted
                                                               standards as prepared by the OECD, it has been agreed
          electronically to DGTonline platform or manually should
                                                               that  CbC Reports should be  submitted in the same
          the online platform  malfunction. The  time limit is  16
                                                               electronic format in every country, namely XML Schema.
          months since the end of the tax year, for CbC Report 2016
                                                               This  is to facilitate automatic exchange of information
          or 12 months after the end of the tax year, for CbC Report
                                                               between countries. The first CbCR information exchange
          2017 and so forth.
                                                               is expected to take place in July/September 2018.
          Publication of treaty partner Countries that            The OECD website reports that  as of 19 December
          are unqualified for information exchange             2017,  there are 68  countries  that  have signed  the
                                                               Multilateral  Competent  Authority Agreement on the
                                                               Exchange of CbC Reports (CbC MCAA).
            To provide legal certainty of CbC Reporting obligations
          by  domestic taxpayer that are not parent entities, PER-
          29 stipulates that at the end of each year the DGT will




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          AUTHORS:                                             DDTC
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                   B. Bawono Kristiaji, S.E., M.S.E., MSc., ADIT  Jl Bulevar Kelapa Gading LA3 No.1
                   Partner, Research and Training Services at DDTC  Summarecon, Kelapa Gading, Jakarta Utara 14240 - Indonesia
                   contact: kristiaji@ddtc.co.id               Phone: + 62 21 2938 5758  I  Fax: + 62 21 2938 5759

                   Romi Irawan, S.E., M.B.A., LL.M Int. Tax    The authors would like to thank Darussalam (Managing Partner
                   Partner, Transfer Pricing Services at DDTC  at DDTC), Danny Septriadi (Senior Partner at DDTC) for their
                   Contact: romi@ddtc.co.id                    valuable input, insight and constructive discussions.

                   Yusuf Wangko Ngantung LL.B, LL.M Int. Tax., ADIT  The information herein is for general purposes only and is not intended to address the
                   Senior Manager, Transfer Pricing Services at DDTC  circumstances of any particular individual or entity. This content should not be used as
                                                               reference for consultation with professional advisors.
                   Contact: yusuf@ddtc.co.id
                                                               © 2018 DDTC is a research and knowledge based taxation institution and a centre of a
                                                               number of taxation business activities units with high standards, consultation services, a
                   Untoro Sejati S.E., Ak., CA., CPA., LL.M Int. Tax  center for review and research, taxation journals, a training centre, a provider of tax law
                                                               documents, a library, and taxation news portal.
                   Senior Manager, Transfer Pricing Services at DDTC  We were established in 2007 by Indonesian well known taxation experts, Darussalam and
                   Contact: untoro@ddtc.co.id                  Danny Septriadi. Our team consists of multidisciplinary specialists, professionals, experts, and
                                                               researchers.
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