The Directorate General of Taxes (DGT) has issued PER-29/PJ/2017 (PER-29) effective 29 December 2017 regarding the procedure and filing requirement of Country by Country Report (CbCR) for taxpayer in Indonesia following the issuance of PMK-213/PMK.03/2016 in 2016 (PMK-213).

Below are some of the key points of PER-29:

1. Taxpayer with below conditions shall be REQUIRED to prepare and submit CbCR in Indonesia:
   • a. Taxpayer is the Resident Ultimate Parent Entity of a corporate group with consolidated gross revenue of Rp11,000,000,000,000 (eleven trillion Rupiah).Further explained that taxpayer classified as above cannot appoint another Constituent Entity as Surrogate Parent Entity to replace its obligation in preparing CbCR. Or
   • b. Taxpayer is a Constituent Entity whose Ultimate Parent Entity is located in a foreign jurisdiction and the country of the Ultimate Parent Entity:
     • Does not require submission of CbCR; or
     • Does not have an agreement with Indonesia subject to exchange of information; or
     • Does have an agreement with Indonesia but the CbCR cannot be obtained by Indonesia Government.
   • Taxpayer classified as Constituent Entity above is NOT REQUIRED to submit CbCR with the following conditions:
     • Taxpayer inform DGT regarding the Constituent Entity chosen as Surrogate Parent Entity by the Ultimate Parent Entity will prepare the Group’s CbCR; and
     • The Surrogate Parent Entity is domiciled in a jurisdiction that requires the submission of CbCR, joined the Qualifying Competent Authority Agreement (QCAA), and Indonesia Government is able to obtained the CbCR from the Surrogate Parent Entity’s jurisdiction.
2. Required documents to be prepared and submitted to DGT
   • Constituent Entity in Indonesia shall submit Notification Form to DJP. The following table summarize the type of documents need to be prepared and submitted by the Ultimate Parent Entity or Constituent Entity.

• The above mentioned documents should be submitted via DJP Online or manually if DJP online inaccessible. The submission made electronically have to be using Extensible Markup Language (XML) file extension. After the submission, Taxpayer should receive a receipt. The receipt then should be attached to the Annual Corporate Income Tax Return (CITR) as a substitute of the actual CbCR.

• CbCR must be available within the following period:
  • 16 months after the end of Fiscal Year for Fiscal Year 2016.3
  • 12 months after the end of Fiscal Year for Fiscal Year 2017 and thereafter.

PDF Version: JL Tax Insight PER-29-PJ-2017_CbCR