Revision of PER-02/PJ/2019: TP Doc Not Needed as Attachments to Annual Corporate Income Tax Returns

Question from Taxpayer and Tax Consultants related to the need to attach Transfer Pricing Documentation (TP Doc) to the Annual Corporate Income Tax Return are answered by the revision made by the Director General of Taxes to the DGT Regulation Number PER-02/PJ/2019 (Distribution II). As previously informed that in accordance with attachment II letter j number 14 Director General of Tax Regulation Number PER-02/PJ/2019 TP Doc must be attached to the Annual Corporate Income Tax Return. TP Doc as regulated by Minister of Finance Regulation Number 213/PMK.03/2016 (PMK-213) consists of Master Documents, Local Documents, and/or Country by Country Report (CbCr).

(Also Read : TP Docs Must Be Attached to Annual Corporate Income Tax?)

On Monday evening (February 4, 2019), the Ortax Editorial Team accesses the page of the Directorate General of Taxes (DG Tax) at the address and there is a Distribution II file PER-02/PJ/2019 (Previously PER-02/PJ/2019).


Source :

The following are the details of the differences in information in attachment II letter j number 14 according to PER-02/PJ/2019 and Distribution II PER-02/PJ/2019

PER – 02/PJ/201914. Transfer Pricing Documents
(Master Documents,
Local Documents, and/or CbCR
Distribusi II PER – 02/PJ/201914. In the form of Summary of Master Documents
and Local Documents and Receipt of
Submission Notification or Submission of CbCR.

With the publication of Distribution II PER-02/PJ/2019, confirms that the summary overview (for Master Documents and Local Documents) and receipts (for submission of Notifications or CbCR submission) are enough as attachments to the Annual Corporate Income Tax Return. Although not required to attach TP report when submitting the Annual Tax Return, the Director General of Taxes is authorized to request Master Documents and Local Documents. Thus, it must be emphasized that Taxpayers must provide TP Doc in accordance with the provisions stipulated in Article 4 of PMK 213.

Source Ortax Editoral

Announcement Number PENG – 5/PJ/2018
Announcement Number PENG – 5/PJ/2018

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