Indonesia releases implementation regulation on Country-by-Country Reports (CbCR) that provides detailed instructions on the procedure and filing of the Country-by-Country Report
Global Tax Update:January 2018/Indonesia
This alert summarizes the key points of PER-29 and provides insight on the Indonesian CbCR requirements for taxpayers in Indonesia.
The Directorate General of Taxes (“DGT”) has issued the long-awaited implementation regulation on Country-by-Country Reports (“CbCR”), i.e. DGT Regulation No. 29/PJ/2017 (“PER-29”) regarding “Procedures for the Management of CbCR”, following the release of the CbCR requirements in early 2017 through Minister of Finance (“MoF”) Regulation No. 213/PMK.03/2016 ( “PMK-213”, please refer to our Tax Alert January 2017 ).
Both PMK-213 and PER-29 broadly align with the reporting requirements and implementing guidelines prescribed by the Organisation for Economic Co-operation and Development (“OECD”) through Action 13 of the Base Erosion and Profit shifting (“BEPS”) project and subsequent guidance issued by the OECD for the purpose of implementation of Country-by-Country Reporting.
PER-29 provides detailed guidance broadly on the following matters:
- which Business Groups/ Multinational Business Groups are required to file the CbCR in Indonesia;
- what is required to be prepared and submitted as part of CbCR filing; and
- timing for preparation and filing of the CbCR in Indonesia.
PER-29 is effective from 29 December 2017 and covers the Indonesian CbCR filing requirement from Fiscal Year (FY) 2016 onwards.