Course 4: Transfer Pricing Documentation

The tax authorities have recently issued a bundle of rulings regarding special relationship transactions, including PER-34/PJ./2010 concerning Corporate Income Tax Return.

The ruling obliged enterprises engaged in related party transactions to fill in the 3A Attachment as a direct statement that the transactions concerned are consistent with the arm’s length principle.

Unfortunately this is not as easy as it seem. Subsequent to the above requirement, enterprises are required to provide evidence of the arm’s length nature of their related party transactions by preparing a transfer pricing documentation. Failure to deliver this documentation on a timely manner, usually results in an imposed correction and corresponding penalties by the tax authorities.

This course will address issues relating to transfer pricing documentation requirements in accordance with the Indonesian legislation and the OECD Guidelines. In the end, participants are expected to be able to prepare and defend their own transfer pricing documentations.

Course 3:
Transfer Pricing on Intangible Property and Intragroup Service

Transaction involving intangible properties and services between related companies has become high profile targets in recent transfer pricing audits. Many Indonesian enterprises pay a large amount of royalties or services to foreign affiliates, for which tax authorities may consider it as inappropriate from transfer pricing point of view.

Consequently, tax authorities could reclassify the transaction concerned and subsequently impose a correction, usually with an additionally penalty sanction.

This course will address issues relating to transfer pricing on intangibles and intra-group services transactions. The purpose of this course is to subsequently prepare participants for transfer pricing documentation requirements regarding these subjects and to defend challenges made by the tax authorities.

Course 2:
International Taxation on Permanent Establishment

International taxation refers to the global tax rules that apply to transactions between two or more countries in the world. The article of OECD Commentary provides for the transaction of cross-border business profit business profits of an enterprise. The income from business activities may be taxed in the source state only if the enterprise has a presence as a Permanent Establishment (hereinafter refers to PE). Thus, there is no taxation in the source State if there is no PE

Course 1:
Transfer Pricing Audit and Defenses

With the introduction of the self assessment system, taxpayers are expected for an increasing responsibility and compliance by the tax authorities. This objective is being enforced by the tax authorities through its tax audit and investigation programs.
This course examines in detail the trigger factors under which a taxpayer would be selected for such verification activities. More importantly, the taxpayer is given guidance on how he should conduct his affairs even before being audited so as to ensure that errors and weaknesses are minimized. Specific issues in documentation, balance sheet and profit & loss accounts will also be discussed.

menyelenggarakan

Seminar Perpajakan Internasioal

atas Bentuk Usaha Tetap

Coming soon on October 2010

Instruktur:

Darussalam, SE, Ak, MSi, LLM Int.Tax

Master of Laws (LL.M) in European & International Taxation dari European Tax College (Tilburg University, Belanda dan Katholieke Universiteit Leuven, Belgia) dengan judul tesis “Critical Analysis on Indonesian Transfer Pricing Rules: a Proposal for Indonesian Transfer Pricing Guidelines”. Wakil Ketua Umum Indonesian International Tax Society (IITS). Dosen di S2 Pajak FISIP UI, PPAK MAKSI FEUI

Danny Septriadi, SE, MSi, LLM Int.Tax

Master of Laws (LL.M) in International Taxation dari Vienna University of Economics & Business Administration, Austria. Berpengalaman menangani sengketa Transfer Pricing di Indonesia dan sebagai penasihat di International Tax Law Research  Association (ILTRA), Belanda. Sekretaris Indonesian International Tax Society (IITS). Dosen di PPAK MAKSI FEUI, S2 Pajak  FISIP UI

He obtained an LL.B degree from Leiden University, Faculty of Law majoring in Tax Law (Fiscaal Recht) and is continuing his study, to become an LL.M candidate from the same university. He has obtained practical tax law experience as junior tax advisor in Howarth de Zeeuw & de Keizer (Howarth Tax Consulting), in Rotterdam, the Netherland. He has been involved in various advices regarding international tax planning, European VAT optimization and implications of expatriates and migrants.

Fasilitas : Sertifikat, Modul materi , Lunch, Coffee Break