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Advance Price Agreement

Advance Price Agreement Template for Indonesia

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Key Requirements PROMPT example:

Advance Price Agreement

"I need an Advance Price Agreement for our Indonesian manufacturing subsidiary that handles complex cross-border transactions with our Malaysian and Singapore entities, focusing on our automotive parts production and distribution network, with the agreement to commence from January 2025."

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Document background
The Advance Price Agreement (APA) is a crucial instrument in Indonesian tax practice, designed to provide certainty and prevent transfer pricing disputes between taxpayers and the Directorate General of Taxes. This document becomes necessary when companies engage in significant related-party transactions and seek to establish agreed-upon transfer pricing methodologies in advance. It is particularly relevant for multinational enterprises operating in Indonesia who wish to minimize transfer pricing risks and ensure compliance with Indonesian tax regulations. The agreement, governed by PMK-22/PMK.03/2020 and other relevant tax laws, typically covers specific transactions for a period of 3-5 years and can be either unilateral (with Indonesian tax authorities only) or bilateral/multilateral (involving foreign tax authorities). The document includes detailed methodologies, critical assumptions, compliance requirements, and annual reporting obligations.
Suggested Sections

1. Parties: Identification of the taxpayer and the relevant tax authority (Directorate General of Taxes of Indonesia)

2. Background: Context of the agreement, including brief description of the business operations and reasons for seeking an APA

3. Definitions: Definitions of key terms used throughout the agreement, including technical transfer pricing terms

4. Scope of Agreement: Specific transactions, products, or services covered by the APA and the period of coverage

5. Transfer Pricing Methodology: Detailed description of the agreed transfer pricing method(s) and how they will be applied

6. Critical Assumptions: Key business and economic conditions upon which the APA is based

7. Term of Agreement: Duration of the APA, including start and end dates

8. Compliance Obligations: Annual reporting requirements and documentation to demonstrate compliance

9. Review and Adjustment Procedures: Processes for periodic reviews and making adjustments if necessary

10. Confidentiality: Provisions regarding the confidentiality of information shared during the APA process

11. Termination and Revision: Circumstances under which the APA can be terminated or revised

12. Governing Law: Specification of Indonesian law as governing law and relevant regulations

13. Execution: Signature blocks and execution requirements

Optional Sections

1. Rollback Provisions: Terms for applying the APA methodology to previous tax years, used when historical tax issues need resolution

2. Dispute Resolution: Specific procedures for resolving disputes, included when standard administrative procedures are insufficient

3. Competent Authority Considerations: Special provisions for bilateral or multilateral APAs involving foreign tax authorities

4. Force Majeure: Provisions for extraordinary events that may affect the application of the APA

5. Language: Specification of controlling language when agreement is in multiple languages, needed for international APAs

6. Compensating Adjustments: Procedures for making adjustments to achieve the agreed pricing outcomes, included when complex pricing mechanisms are involved

Suggested Schedules

1. Schedule A - Covered Transactions: Detailed list and description of all transactions covered by the APA

2. Schedule B - Transfer Pricing Methodology Details: Technical details of the pricing methodology, including formulas and calculations

3. Schedule C - Critical Assumptions Analysis: Detailed analysis of each critical assumption and its impact

4. Schedule D - Annual Compliance Report Template: Format and requirements for annual compliance reporting

5. Appendix 1 - Financial Projections: Relevant financial projections supporting the transfer pricing methodology

6. Appendix 2 - Functional Analysis: Detailed analysis of functions, assets, and risks of the parties

7. Appendix 3 - Comparability Analysis: Documentation of comparable transactions or companies used in the analysis

8. Appendix 4 - Supporting Documentation: Additional documentation supporting the APA application and methodology

Authors

Alex Denne

Head of Growth (Open Source Law) @ tiktok成人版 | 3 x UCL-Certified in Contract Law & Drafting | 4+ Years Managing 1M+ Legal Documents | Serial Founder & Legal AI Author

alex.den.21@genieai.co
Relevant legal definitions














































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Relevant Industries

Manufacturing

Technology

Pharmaceuticals

Automotive

Consumer Goods

Energy and Resources

Financial Services

Telecommunications

E-commerce

Chemical Industry

Mining and Minerals

Agricultural Products

Industrial Products

Professional Services

Relevant Teams

Tax

Finance

Legal

Treasury

International Business

Compliance

Risk Management

Transfer Pricing

Corporate Affairs

Financial Planning and Analysis

Accounting

Internal Audit

Relevant Roles

Tax Director

Chief Financial Officer

Transfer Pricing Manager

International Tax Manager

Tax Compliance Manager

Finance Director

Corporate Controller

Head of Tax

Tax Counsel

Financial Planning Manager

Treasury Manager

International Business Director

Compliance Officer

Risk Management Director

Group Financial Controller

Industries








Teams

Employer, Employee, Start Date, Job Title, Department, Location, Probationary Period, Notice Period, Salary, Overtime, Vacation Pay, Statutory Holidays, Benefits, Bonus, Expenses, Working Hours, Rest Breaks, 聽Leaves of Absence, Confidentiality, Intellectual Property, Non-Solicitation, Non-Competition, Code of Conduct, Termination, 聽Severance Pay, Governing Law, Entire Agreemen

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