Transfer pricing and the Covid-19 phenomenon:         An Indonesian perspective

The article offers a practical look at the impact of the COVID-19 pandemic on transfer pricing considerations in Indonesia and steps to navigate these challenges.

The COVID-19 pandemic has resulted practical challenges in the application of the arm's length principle. Earlier in December 2020, the OECD published its 'Guidance on the Transfer Pricing Implications of the COVID-19 pandemic' ("OECD Guidance"). This article discusses four priority issues in OECD Guidance reflecting the main challenges that MNEs encounter in complying with transfer pricing regulations amidst the pandemic and several key transfer pricing considerations that can be taken by Indonesian taxpayers to navigate these challenges.

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